Effective from 1 January 2025, Singapore will implement a new tax system to enforce a minimum effective tax rate of 15 percent on qualifying profits, in accordance with the BEPS Pillar 2 initiative. This will apply to multinational enterprise (MNE) groups with an ultimate parent entity (UPE) that has recorded annual revenue of EUR 750 million or more in their consolidated financial statement in at least two of the four preceding financial years, subject to certain exclusions.
UPEs of such MNE groups must notify the Singapore tax authorities of their liability to register under the new act and file tax returns on their top-up tax liability.
Additionally, all registered MNE groups must file a GloBE Information return (GIR) with Singapore unless it is filed with another jurisdiction. Even if filed elsewhere, an annual GloBE notification must be submitted to Singapore tax authorities to inform them of the foreign UPE's identity and the jurisdiction where the GIR is filed.
Pillar Two brings unprecedented changes to the global tax system and is rapidly evolving around the globe. A&M tax professionals are ready to guide businesses on analysing the rules, extracting relevant data and meeting their obligations under new Singapore tax system.
The EU Tax Omnibus: a major simplification of the EU direct tax framework
July 23, 2026
On 24 June 2026, the European Commission published its “Tax Omnibus” proposal (“Proposal”) — a single proposed Council Directive amending six EU direct tax directives, with an estimated EUR 6.6 billion in annual compliance cost savings.
EU DAC Recast Proposal: What the European Commission’s simplification agenda means for cross-border tax reporting
July 23, 2026
On June 24, 2026, the European Commission published a proposal to recast the Directive on Administrative Cooperation in the field of taxation (DAC) as part of an ambitious tax simplification package designed to simplify existing EU tax rules and reduce compliance for businesses.
Delhi High Court Rules that Reimbursement of Salary Cost for Seconded Employees Constitutes FTS Where Home Entity Retains Lien and Overarching Control
July 23, 2026
The Delhi High Court (HC), on June 18, 2026, in Ernst & Young U.S. LLP (EY US) has, inter alia, ruled that in the given facts, EY US retained ‘lien’ over seconded employees in India and cost-to-cost reimbursements of such seconded employees were taxable as Fees for Technical Services (FTS) under both Section 9(1)(vii) of the Income-tax Act, 1961 (Act), and Article 12 of the India–US Tax Treaty (Tax Treaty).
Thai Customs Introduces Revised Reward System: Key Implications for Business
July 10, 2026
New Thai Customs rewards rule reshapes officer allocations but preserves core incentives, keeping enforcement pressure high. Reassess exposure now, especially on valuation, tariff codes, origin claims, and related-party payments.
