Public Consultation on Proposed Multinational Enterprise (Minimum Tax) Bill and Income Tax (Amendment) Bill 2024

    The Ministry of Finance is proposing a Multinational Enterprise (Minimum Tax) Bill and subsidiary legislation, as well as legislative amendments to the Income Tax Act 1947 (“ITA”). Interested parties are invited to provide feedback on the proposed Multinational Enterprise (Minimum Tax) Bill and the subsidiary legislation, as well as the proposed Income Tax (Amendment) Bill 2024 from 10 June to 5 July 2024.

2.  The proposed Multinational Enterprise (Minimum Tax) Bill and the subsidiary legislation will implement a Domestic Top-up Tax (“DTT”) and the Income Inclusion Rule (“IIR”) under Pillar Two of the Base Erosion and Profit Shifting (“BEPS”) 2.0 initiative, as announced in the 2024 Budget Statement on 16 February 2024. The proposed Multinational Enterprise (Minimum Tax) Bill, if passed into law, will be construed as one with the ITA. Certain provisions, such as administration, enforcement and appeals that apply under the ITA, will also apply to DTT and the Multinational Enterprise Top-up Tax (“MTT”)¹, with modifications set out under the proposed Bill. The proposed Bill also contains amendments to the ITA to clarify the income tax treatment of taxes imposed by Singapore and other jurisdictions under Pillar Two of the BEPS 2.0 initiative. 

3.  The proposed Income Tax (Amendment) Bill 2024 includes 22 amendments to the ITA. The proposed amendments cover:

a.  tax measures announced in the 2024 Budget Statement (15 amendments); and

b.  changes arising from MOF’s periodic review of the income tax regime to better reflect policy objectives and to improve tax administration (seven amendments).

Submission of feedback via email from 10 June to 5 July 2024

4.  The public can access the public consultation documents, including the proposed Multinational Enterprise (Minimum Tax) Bill and the subsidiary legislation, as well as the proposed Income Tax (Amendment) Bill 2024, on the Ministry of Finance's website ( www.mof.gov.sg) and the REACH consultation portal ( www.reach.gov.sg).

5.  Interested parties are requested to use the template to submit their comments on the proposed Bills and the subsidiary legislation by 5 July 2024.

Issued by:

Ministry of Finance

Singapore

10 June 2024 

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[1] IIR imposed by Singapore is referred to as the MTT in the proposed Multinational Enterprise (Minimum Tax) Bill.