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For financial years (FYs) commencing on or after 1 January 2017, multinational companies (MNEs) with their headquarters in Singapore are required to produce and submit CbC Reports to IRAS if they meet certain requirements.

What is Country-by-Country Reporting (CbCR)?

The Organization for Economic Co-operation and Development (OECD) announced Country-by-Country Reporting (CbCR) as a form of reporting by multinational enterprises (MNEs) in the Base Erosion and Profit Shifting (BEPS) Action 13 Report. For financial years (FYs) commencing on or after 1 January 2017, Singapore-headquartered MNEs must produce and submit CbC Reports to IRAS by Singapore’s commitment to implement specific measures under the BEPS Project.

Qualifying Competent Authority Agreement

The Multilateral Competent Authority Agreement on the exchange of CbC Reports (the “MCAA CbCR”) was signed by Singapore on 21 June  2017. Singapore will be able to effectively build an lextensive network of exchange partnerships for the automated exchange of CbC Reports, thanks to the signing of the MCAA CbCR. View the press release.

The Convention on Mutual Administrative Assistance in Tax Matters  is the foundation for the multilateral framework agreement known as the MCAA CbCR. It gives a consistent and effective framework to make the automatic exchange of CbC Reports possible. The MCAA CbCR provides that, if both parties agree, the parties to the MCAA shall automatically exchange CbC Reports on a bilateral basis.

Under the MCAA, tax authorities of nations with which Singapore has established bilateral AEOI relationships will receive CbC reports submitted to IRAS. Not all MCAA’s signatories have yet given complete or comprehensive notices of their proposed exchange relationships. Over time, some jurisdictions may additionally strengthen their exchange ties. Therefore, Singapore will enter into more exchange relationships not included in the list of exchange relationships shown below. Please visit the OECD website for further details.

CbCR Filing Requirements

Who needs to file the CbC Report?

All entities in the Singapore MNE group must file a CbC Report, which the group’s ultimate parent entity will submit. If the MNE group satisfies each of the following requirements, it must submit the CbC Report:

1. The MNE group’s ultimate parent company is a Singaporean tax resident;
2. Consolidated group revenue for the MNE group in the preceding financial year is at least S$1,125 million; and
3. The MNE group has businesses or subsidiaries in at least one international country.

When CbC Report should be submitted?

Within 12 months of the end of the financial year for the ultimate parent entity, the CbC Report must be submitted to IRAS.

For CbCR, the financial year starting on or after 1 January 2021, but before 1 January 2022 is referred to as FY 2021.

Notification of Filing Obligation

Every year, IRAS notifies the reporting entities by letter of their requirement to submit a CbC Report to IRAS for the prior FY. For example, by 31 July 2022, IRAS will send notification letters to the reporting entities for the FY 2021 CbC Report.

If you must submit a CbC report for a fiscal year (FY) based on the criteria outlined in the section above on “CbCR Filing Requirements,” but you have not received a letter from IRAS by 31 July of the following year, get in touch with them right away by sending an email to ct_transfer_pricing@iras.gov.sg.

Reporting Entities that are obliged to submit a CbC report must send the following details to IRAS via email at

 ct_transfer_pricing@iras.gov.sg at least three months before the submission deadline:

• The ultimate parent entity’s name and UEN (i.e. Reporting Entity)
• (DD/MM/YYYY to DD/MM/YYYY) is the ultimate parent entity’s financial reporting period.
• Name and phone number of the contact person
• Contact person’s email (if different from that used to provide your reply)

The foreign Reporting Entity that will be filing a CbC report in the foreign jurisdiction does not need to be disclosed to IRAS by a Singapore constituent entity of a foreign MNE Group.

How to Submit the CbC Report

The predominant CbCR XML Schema is shown in the table below, and Reporting Entities will need to have procedures in place to collect and prepare the necessary data in line with it. Any other format for data submission to IRAS will not be approved.

The following information must be included with the email submission of the reporting entity’s XML CbC report to ct_transfer_pricing@iras.gov.sg:

• Name of the ultimate parent entity (i.e. Reporting Entity)
• Financial reporting period (DD/MM/YYYY to DD/MM/YYYY)
• If applicable, a letter of authority for a third party (e.g. a tax agent) to file on your behalf, if the third party is different from the one you have authorized via Corppass

The XML CbC report needs to be password-protected, zipped (file extension must be in zip format *.zip), and named with the Reporting Entity’s name (e.g. ABC Ltd.zip). Please send us the password for your CbC report via FormSG at FormSG after you have emailed it to us.

Note: Please use a strong password. It is recommended that the password should be:

• At least twelve characters; and
• Alphanumeric with at least one upper and lower case alphabet, number, and symbol (e.g. PCrj57#u6Ew!).

To learn more about Singapore incorporation, economy, banking, etc., feel free to call/WhatsApp us at +65 90612851 or email us at aceglobalacct@gmail.com. Alternatively, you may leave us a reply using our contact form below.

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