In February 2024, a suite of tax measures was announced in Singapore’s Budget 2024, including the upcoming implementation of Pillar Two of the Base Erosion and Profit Shifting 2.0 (“BEPS 2.0“) on 1 January 2025.
On 10 June 2024, the Ministry of Finance (“MOF“) launched two public consultations on two Bills to implement the tax measures from Budget 2024:
- Consultation on the Multinational Enterprise (Minimum Tax) Bill (“MNE Bill“) and the Multinational Enterprise (Minimum Tax) Regulations 2025, regarding the implementation of BEPS 2.0 Pillar Two; and
- Consultation on the Income Tax (Amendment) Bill 2024 (“ITA Bill“), which proposes 15 amendments to the Income Tax Act 1947 (“ITA“) to effect measures announced in Budget 2024 and seven amendments arising from MOF’s periodic review of Singapore’s income tax regime.
The MNE Bill, in particular, signals a major change to Singapore’s tax regime by introducing a minimum effective tax rate of 15% for large multinational entity (MNE) groups pursuant to the Global Anti-Base Erosion Model Rules (GloBE Rules).
The consultations will run from 10 June 2024 to 5 July 2024, with MOF to provide a summary of responses in September 2024.
In this Update, we provide an overview of the two Bills.
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