Singapore Tax Update: Key Legislative Developments in October 2024

In a major development in the tax regime in Singapore, the Singapore Parliament approved two major bills on October 15, 2024. These are the Multinational Enterprise (Minimum Tax) Bill and the Income Tax (Amendment) Bill, which introduce significant changes in tax to ensure compliance with global frameworks while supporting local economic activities.

For businesses operating in Singapore, it’s imperative to remain abreast of these tax updates to ensure compliance. Consulting established companies providing professional taxation services in Singapore, enterprises can adhere to the latest regulations.

In this edition, check out what these new updates are, and how they can impact your business.

1. Multinational Enterprise (Minimum Tax) Bill

The legislation in Singapore introduced two new top-up taxes under the Base Erosion and Profit Shifting (BEPS) initiative of OECD. The goal of this initiative is to make sure Singapore complies with international tax frameworks. These measures are likely to be implemented from January 1, 2025. This legislation introduces two new top-up taxes under the OECD’s Base Erosion and Profit Shifting (BEPS) initiative to align Singapore with international tax frameworks.

Key Features:

a. Domestic Top-up Tax (DTT)

• Targets entities in Singapore within large MNE groups.
• Imposed if the effective tax rate of the group in Singapore is below 15%.

b. Multinational Enterprise Top-up Tax (MTT)

• Applicable to MNE groups with their headquarters in Singapore.
• Imposed if the entities of the company in foreign jurisdictions have an effective tax rate below 15%.
• The MTT ensures that the global effective tax rate for the group is increased to a minimum threshold of 15%.

It applies only to large MNE groups with at least €750 million as the annual group revenue in two or more of the four preceding financial years.

Compliance and Enforcement

The Comptroller of Income Tax is authorized to administer, collect, and enforce the MTT and DTT.

Offences under the new norms include:

• Failure to maintain proper records Tax evasion
• Obstruction to the duties of the Comptroller

These powers are already in place under the Income Tax Act 1947 to ensure that the IRAS (Inland Revenue Authority of Singapore) can effectively enforce compliance.

2. Income Tax (Amendment) Bill

This bill introduces tax measures announced in the 2024 Budget Statement last February, along with some periodic updates to the income tax regime in Singapore. The provisions under this bill are presented below.

a. Refundable Investment Credit (RIC)

The RIC has been designed to encourage high-value economic activities in Singapore. It provides tax credits for local expenditures, like:

• Capital investments
• Research and development (R&D)
• Manpower training
• Freight and logistics

Eligible Activities

• Establishing or expanding manufacturing facilities
• Setting up headquarters and services operations
• Conducting R&D and innovation projects
• Commodity trading
• Decarbonization initiatives

How It Works

• Tax credits offset corporate income tax payable
• Unused credits are refunded within four years of the qualifying claim for expenditures

b. Renovation and Refurbishment (R&R) Scheme Enhancements

The scheme allows businesses to deduct R&R expenses, which are typically not deductible as capital expenses. From Year of Assessment (YA) 2025, qualifying expenses will include designer and professional fees.

Standardized Expenditure Cap Period

Previously, the cap period used to vary, based on the time when a business made its first claim. Currently, the standardized rate involves a three-year cap of SGD 300,000, starting from YA 2025 to YA 2027. Businesses can now opt to claim the entire R&R deduction in one YA instead of spreading it over three YAs. This significantly improves their cash flows.

Why These Changes Matter for Businesses

Now, let’s understand how these changes in the tax regime in Singapore are likely to affect businesses.

1. Global compliance

The DTT and MTT ensure Singapore remains compliant with the global tax framework of BEPS (Base Erosion and Profit Shifting) of the OECD. This will safeguard its reputation as a leading financial hub.

2. Encouraging investments

The RIC provides incentives to businesses to channel their investments into activities driving innovation and economic growth in Singapore while maintaining sustainability.

3. Greater flexibility

New updates to the R&R Scheme now provide businesses with greater flexibility and control over their financial management, particularly in areas sensitive to cash flow.

What Businesses Should Do Next?

Successful businesses are looking to adopt a proactive stance and assess the updated tax structures. For large MNEs, it’s necessary to evaluate their global tax positions and maintain compliance with the DTT and MTT requirements by 2025.

Another challenge involves detecting qualifying expenditures early to maximize benefits under the RIC framework. Forward-thinking businesses are already reaching out to leading companies providing professional taxation services in Singapore, like the IMC Group. Consulting these experts can help in optimizing their tax deductions for expenses related to renovation and refurbishments. With a trusted tax advisory partner providing accurate guidance, businesses in Singapore can remain compliant amidst the new tax regime.