Summary of Responses to Public Consultation on the Proposed Finance (Income Taxes) Bill 2025

The Ministry of Finance (“MOF”) invited the public to provide feedback on the proposed Finance (Income Taxes) Bill 2025 from 18 June to 11 July 2025.

2.      The proposed Bill covered amendments to the:

a) Income Tax Act 1947 (“ITA”) to effect tax measures announced in the 2025 Budget Statement as well as changes arising from MOF’s periodic review of Singapore’s income tax system to better reflect policy objectives and to improve tax administration; and

b) Multinational Enterprise (Minimum Tax) Act 2024 (“MMTA”) to effect clarifications that are in accordance with the Pillar Two Global Anti-Base Erosion Model Rules, commentary and administrative guidance (“GloBE rules”), expansion of regulation-making powers necessary to operate GloBE rules and miscellaneous amendments.

3.      Feedback received on the proposed legislative amendments to the ITA mostly pertained to: 

a) Enhancement of section 13W of the ITA that provides upfront certainty of non-taxation of companies’ disposal gains;

b) Introduction of a tax deduction for payments made under an approved cost-sharing agreement for innovation activities; and

c) Identification of related parties of trusts and partnerships for transfer pricing purposes and exclusion of non-commercial private trusts from transfer pricing requirements.

4.      MOF has also received clarifications on the proposed legislative amendments to the MMTA and suggestions to simplify or align the MMTA with the GloBE rules.

5.      MOF’s responses to the key feedback are in the Annex.

6.      We thank all respondents for their feedback.