Country-by-Country Reporting (CbCR) is a form of reporting by multinational enterprises (MNEs) initiated by the Organisation for Economic Co-operation and Development (OECD) in the Base Erosion and Profit Shifting (BEPS) Action 13 Report. In keeping with Singapore’s commitment to implement certain measures under the BEPS Project, Singapore-headquartered MNEs meeting certain conditions are required to prepare and file CbC Reports to IRAS for financial years (FYs) beginning on or after 1 Jan 2017.
Some jurisdictions would be implementing CbCR for FY beginning on or after 1 Jan 2016. To address the transition issue arising from this, affected Singapore-headquartered MNEs may file a CbC Report for FY beginning on or after 1 Jan 2016 to IRAS on a voluntary basis, i.e. Voluntary Filing.
A CbC Report of the MNE group will include information on the group’s global allocation of the income and taxes paid in different countries and other financial data. CbC Reports submitted to IRAS will be provided to tax authorities of countries with which Singapore has signed bilateral agreements for automatic exchange of CbCR information. CbC Reports may be used by Singapore and other tax authorities in evaluating transfer pricing risks and other BEPS related risks.
Who needs to file the CbC Report
The ultimate parent entity of the Singapore MNE group will be required to file a CbC Report for all entities in the group. The MNE group is required to submit the CbC Report if it meets all of the following conditions:
1. The ultimate parent entity of the MNE group is tax resident in Singapore;
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 subsidiaries or operations in at least one foreign country.
CbC Report should be submitted to IRAS within 12 months from the end of the ultimate parent entity's financial year.
CbC report must be submitted based on the format specified in Paragraph 5 of the CbCR e-Tax Guide (440KB). Please refer to the e-Tax Guide (440KB) for details on the report format and information to be submitted.
New! Reporting Entities will need to have processes in place to collate and prepare the required data in accordance with the prevailing CbCR XML Schema set out in the table below. Data submitted to IRAS in any other format will not be accepted.
CbCR XML Schema User Guide for Tax Administrations and Taxpayers (OECD’s publication date: 22 March 2016)
IRAS’ Supplementary Instructions for Preparing CbCR Reporting Data File (For CbCR XML Schema version 1.0)
* Current version provided by OECD. OECD has indicated that it will release a revised version in May 2017.
New! IRAS will develop an IT system to collect and exchange the CbCR information. Details on the mode of submission of CbC Report will be released at a later date.
New! Reporting Entities may file a CbC Report for FY 2016 to IRAS on a voluntary basis. The FY 2016 CbC Report must be submitted in accordance with the prevailing CbCR XML Schema (refer the section on How to Submit the CbC Report for the XML Schema). Data submitted to IRAS in any other format will not be accepted.
New! Details of the mode of submission of your FY 2016 CbC Report will be released by the end of September 2017.
If a company required to file the CbC Report fails to do so by the due date, IRAS may take the following actions:
A company which provides false or misleading CbC information may face the following consequences:
For more details, please refer to our e-Tax guide on CbCR (440KB).
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