Summary of Responses to Public Consultation on the Draft Multinational Enterprise (Minimum Tax) Bill and Income Tax (Amendment) Bill 2024

    The Ministry of Finance (“MOF”) invited the public to provide feedback on the draft Multinational Enterprise (Minimum Tax) Bill and subsidiary legislation, as well as the draft Income Tax (Amendment) Bill 2024 from 10 June to 5 July 2024.

Multinational Enterprise (Minimum Tax) Bill

2.   The draft 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.

3.   MOF received feedback on policy, technical and administration aspects of the DTT and IIR, and their interactions with the general corporate income tax regime. MOF’s responses to the key feedback are in

Annex A

.

4.   As certain aspects of the Pillar Two rules are still being developed, MOF and the Inland Revenue Authority of Singapore (“IRAS”) will continue to monitor ongoing international developments and refine the parameters of our income tax regime where necessary.

Income Tax (Amendment) Bill 2024

5.   The draft Income Tax (Amendment) Bill 2024 proposed legislative amendments to the Income Tax Act 1947 (“ITA”) to effect: (a) tax measures announced in the 2024 Budget Statement; and (b) changes arising from MOF’s periodic review of Singapore’s income tax regime.

6.   MOF received feedback on the proposed legislative amendments, in particular, on the following measures:

a)   Introduction of the Refundable Investment Credit (“RIC”);

b)   Introduction of an alternative basis of tax where the qualifying income of shipping entities will be taxed by reference to net tonnage; and

c)   Clarification of the tax treatment of real estate investment trust (“REIT”) units held by REIT managers.

7.   MOF’s responses to the key feedback are in

Annex B

.

8.   We thank all respondents for their feedback.