If you are the company secretary of a Singapore subsidiary that sits inside a large multinational group, a new compliance item has almost certainly landed on your desk this year, even if nobody labelled it as a “corporate secretarial” task. Singapore’s Domestic Top-up Tax (DTT) and Multinational Enterprise Top-up Tax (MTT), introduced under the Multinational Enterprise (Minimum Tax) Act 2024 to give effect to the OECD’s Pillar Two / BEPS 2.0 framework, apply to financial years starting on or after 1 January 2025. For groups that meet the revenue threshold, a one-time registration with the Inland Revenue Authority of Singapore (IRAS) is now compulsory, and the deadline for many groups has already passed or is fast approaching.

Most of the commentary on Pillar Two is written for group tax directors and CFOs sitting in a regional or global headquarters. This article takes a different angle. It is written for the person actually based in Singapore, holding the statutory books, who is being asked by the group’s tax function to “just confirm a few things” for the registration form and the GloBE Information Return (GIR). That person is very often the company secretary, sometimes working alongside the finance manager, and the tasks involved are not trivial: they touch board reporting, statutory registers, resolutions, and the accuracy of information filed with a Singapore regulator under your own signature block.

This piece sets out what has been verified about the thresholds, dates and penalties, and then focuses squarely on what a Singapore subsidiary’s company secretary and directors need to do operationally, rather than repeating a generic “what MNCs must do” explainer.

What the Domestic Top-up Tax and MTT Actually Cover

The Domestic Top-up Tax and the Multinational Enterprise Top-up Tax are Singapore’s implementation of the Pillar Two global minimum tax. Both are designed to bring the effective tax rate of large MNE groups up to the internationally agreed 15% floor, wherever their entities are located.

Who Is Caught: the EUR 750 Million Threshold

The rules apply to MNE groups with annual consolidated group revenue of EUR 750 million or more, tested against at least 2 of the preceding 4 financial years. This is the standard OECD GloBE scoping test, and Singapore has adopted it without modification. If your subsidiary’s ultimate parent entity reports consolidated revenue at or above this threshold in the relevant test years, the subsidiary is considered in scope, regardless of how small the Singapore entity itself is.

DTT applies to the Singapore-resident entities of an in-scope group where the group’s effective tax rate in Singapore, computed on a GloBE basis, falls below 15%. MTT applies where the group is parented in Singapore and its foreign entities are taxed below 15% in their home jurisdictions. Both took effect for financial years beginning on or after 1 January 2025, which for a calendar-year entity means the year ended 31 December 2025 is already the first affected year.

The Registration Requirement: Portal, Deadline and Penalty

Registration under the Multinational Enterprise (Minimum Tax) Act is a one-time obligation for each in-scope group, separate from the eventual filing of the GIR and payment of any top-up tax due. IRAS opened its registration portal for MTT, DTT and the GIR in May 2026.

When Registration Is Due

The statutory deadline is 6 months after the end of the group’s first affected financial year. For a group whose first affected financial year ended 31 December 2025, the registration form is due by 30 June 2026. Groups with different financial year-ends should calculate their own 6-month window from their own first affected year-end rather than assuming the 30 June 2026 date applies to them.

The Cost of Missing the Deadline

Failure to register on time carries a fine of up to S$10,000. Beyond the flat penalty, the Act also provides for surcharges and other offences (including in relation to record-keeping and obstruction of the Comptroller) where non-compliance is more serious or wilful, and Singapore tax legislation of this kind typically reserves imprisonment for cases of deliberate evasion or fraud rather than a simple missed administrative deadline. Because the precise sentencing provisions sit deep in the Multinational Enterprise (Minimum Tax) Act 2024 and its subsidiary legislation, any director or company secretary dealing with a genuinely overdue or disputed registration should have the group’s tax advisers check the current wording on Singapore Statutes Online rather than relying on a general summary. What is clear and confirmed is the S$10,000 exposure for a missed registration, which is reason enough to treat the deadline as a hard one.

The registration itself, and the underlying rules, are set out by IRAS, with the enabling legislation and Ministry of Finance guidance available via MOF. These are the only authoritative sources; treat commentary from tax advisory firms, however reputable, as a summary of that primary material.

Why This Lands on the Company Secretary’s Desk

On paper, Pillar Two compliance is a tax matter, and the substantive computations will sit with the group’s tax function, often supported by external advisers. In practice, a great deal of the groundwork is administrative, and administrative groundwork for a Singapore private company runs through the company secretary. Three things make this unavoidable.

First, the registration form itself asks for constitutional and governance details: entity names, UEN, registered office, financial year-end, and details of the authorised contact person, all of which sit in the company secretary’s records rather than the group tax team’s spreadsheets. Second, the GIR eventually required from in-scope entities draws on statutory and management accounts data that needs to be reconciled against the company’s own books, which is a natural extension of the company secretary’s existing role in coordinating the annual return and financial statements. Third, and often overlooked, the board needs to be told what is happening and, in many groups, needs to pass a resolution authorising a specific person to submit the registration and liaise with IRAS on the group’s behalf. That resolution, its minute, and the update to the company’s registers are squarely company secretarial work.

Data Collection for the GloBE Information Return

Even before the GIR itself falls due, the registration process forces an early collation exercise: confirming the ultimate parent entity, the group structure chart as it applies to the Singapore entity, the financial year-end used for GloBE purposes, and whether the Singapore entity is a reporting entity or is relying on another group entity to file. The company secretary is usually the person holding the most current and accurate version of the corporate structure, given their role in maintaining the register of registrable controllers and the register of members, so pulling this together accurately is naturally theirs to lead or co-ordinate, even if the tax figures themselves are supplied by the finance or tax team.

Board Reporting and Resolutions

Directors of the Singapore subsidiary remain legally accountable for the company’s compliance obligations even where the substantive Pillar Two analysis is performed at group level. A short board paper explaining the DTT/MTT exposure, the registration deadline, and who has been authorised to act is good governance and should be minuted at the next board meeting, or by way of directors’ resolution in writing if a meeting is not scheduled in time. Where IRAS registration requires nomination of an authorised person or filer, a formal board resolution recording that authorisation protects both the company and the individual concerned.

Updating Statutory Registers and Internal Records

Once registration is complete, the company secretary should record the registration reference, the authorised contact person, and the relevant dates in the company’s internal compliance calendar and statutory file, alongside existing obligations such as the annual return, AGM, and corporate tax filings. This is also a sensible moment to review whether the company’s statutory duties under the Companies Act checklist has been updated to reflect this new recurring obligation, since Pillar Two compliance is not a one-off event but an ongoing annual cycle of registration, data submission, and eventual GIR filing.

A Practical Checklist: What Your Company Secretary Needs From You

Directors and group finance teams can make this process considerably smoother by proactively supplying the following to their Singapore company secretary:

  • Confirmation of whether the ultimate parent group’s consolidated revenue has met the EUR 750 million threshold in at least 2 of the preceding 4 financial years.
  • The group’s financial year-end used for GloBE purposes, and whether it matches the Singapore entity’s own financial year-end.
  • A current group structure chart identifying the ultimate parent entity and the Singapore entity’s place within it.
  • Confirmation of whether the Singapore entity is itself the GIR filer or relies on another group entity, and the identity of the group’s lead tax contact.
  • The name of the individual to be authorised as the registered contact person for the IRAS portal, together with a board resolution authorising that appointment.
  • Instructions on whether a related Singapore entity has already registered on behalf of the group, to avoid duplicate registration.
  • A note of any deferred tax or provisioning implications for the statutory accounts, to be flagged to the auditors and reflected consistently with the company’s FRS 12 deferred tax treatment.

Coordinating with the Group Tax Function

Because the underlying GloBE computations are complex and typically performed centrally, the Singapore company secretary’s most valuable contribution is often simply being the reliable local point of contact: confirming entity-level facts quickly, keeping registers current, and making sure the board is properly informed and has authorised what needs authorising. It is worth setting up a short recurring check-in with the group tax function, even quarterly, so that registration status, GIR timelines, and any changes to the group’s scope (for example, following an acquisition that pushes consolidated revenue over the threshold) are tracked centrally rather than discovered close to a deadline.

This coordination role sits alongside other cross-border tax administration that Singapore company secretaries are increasingly expected to manage, from supporting Certificate of Residence applications and board residency requirements for treaty relief, to coordinating responses under the CRS 2.0 reporting regime for entities that qualify as reporting financial institutions. Pillar Two registration is best treated as one more strand of this same broader compliance calendar rather than a standalone crisis.

Looking Ahead

Groups should also keep an eye on how Pillar Two interacts with other recent Singapore tax changes affecting the corporate tax position, including the enhanced Corporate Income Tax Rebate, since the interaction between rebates, incentives and the GloBE effective tax rate calculation is one of the more technical areas the group’s tax advisers will need to work through. For company secretaries and directors, the immediate priority is simpler: confirm whether your group is in scope, register on time if it is, and make sure the board’s decisions are properly documented along the way.

Businesses reviewing their broader financial governance as part of this exercise may also find it useful to read more general commentary on managing company finances in Singapore, and founders and directors thinking about their own long-term financial planning alongside these corporate obligations are often better served by seeking independent guidance on sound financial management rather than treating it as an afterthought to compliance work.

Getting the registration right is a small task in isolation, but it sets the tone for how smoothly the far larger GIR filing exercise goes in the following year. A company secretary who has kept clean records, obtained the right board authorisations, and stayed close to the group tax function will find that far easier than one starting from scratch under deadline pressure.

To speak with the team at Raffles Corporate Services, you can email [email protected] or call, SMS, or WhatsApp +65 8501 7133. We are happy to assist with any queries.

The Editorial Team, Raffles Corporate Services