With the implementation of OECD Pillar Two – Global Anti-Base Erosion (GloBE) Rules and Singapore’s adoption of the global minimum tax regime from 2025, multinational groups in Singapore face significant changes in their tax landscape.
This course by ISCA provides practical insights into the application of the GloBE Rules, focusing on both Singapore HQ groups as well as in-scope MNE groups having a presence in Singapore. Through real-world examples and case studies, participants will gain a clear understanding of compliance requirements, tax exposure, and strategic considerations in adapting to the evolving international tax framework.
A Highlight of Key Areas:Introduction to Pillar Two – GloBE Rules
- Background and objectives of OECD BEPS 2.0 initiative
- Overview of GloBE Rules – Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), and Qualified Domestic Minimum Top-up Tax (QDMTT)
- Scope and applicability – threshold requirements (EUR 750 million consolidated revenue)
- Key definitions and concepts (covered taxes, GloBE income, jurisdictional blending)
Computation of Effective Tax Rate and Top-Up Tax
- Step-by-step approach to ETR computation under GloBE
- Broad overview of top-up tax computation and allocation mechanisms
- Substance-based income exclusion rules
- Safe harbour provisions (transitional CbCR safe harbour)
- Exercise: Computation of ETR and top-up tax for a sample Singapore-headquartered group
Singapore Implementation and Implications for HQ Groups
- Overview of Singapore’s adoption of Pillar Two (from 2025)
- Interaction with Singapore’s existing tax incentives and regimes
- Impact on effective tax rates of Singapore entities
- Considerations for Singapore HQ groups with overseas subsidiaries
- Discussion: Practical challenges faced by Singapore-based MNCs
Global Implementation and Compliance Requirements
- Overview of global implementation status, local compliance requirements
- Interaction between IIR, UTPR, and QDMTT across jurisdictions
- GloBE Information Return – key components and timelines
- Penalties and risks of non-compliance
- Coordination between group entities across jurisdictions; data and reporting challenges
- Exercise: Identifying data gaps and compliance roadmap
Strategic Considerations and Tax Planning in a Pillar Two Environment
- Reassessment of group structures and holding arrangements
- Review of intercompany transactions and financing structures
- Managing impact on tax incentives and substance requirements
- Alignment with broader business and operational strategies
- Discussion: Sample Case Study on Tax Optimisation in a Pillar Two Environment