Country-by-Country Reporting (CbCR)

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 jurisdictions and other financial data. CbC Reports submitted to IRAS will be provided to tax authorities of jurisdictions with which Singapore has qualifying competent authority agreements for the 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.

Qualifying Competent Authority Agreement

New!On 21 June 2017, Singapore signed the Multilateral Competent Authority Agreement on the exchange of CbC Reports(“MCAA CbCR”). The signing of the MCAA CbCR will enable Singapore to efficiently establish a wide network of exchange relationships for the automatic exchange of CbC Reports. For more details, the press release is available here.


The MCAA CbCR is a multilateral framework agreement based on the Convention on Mutual Administrative Assistance in Tax Matters. It provides a standardised and efficient mechanism to facilitate the automatic exchange of CbC Reports. Under the MCAA CbCR, signatories to the MCAA will automatically exchange CbC Reports with one another on a bilateral basis if both parties are mutually agreeable. 


CbC reports submitted to IRAS will be provided to tax authorities of jurisdictions with which Singapore has established bilateral AEOI relationships under the MCAA. The list of exchange relationships will be updated when ready.

  1. What is the MCAA on CbC Reports?

    The MCAA CbCR is a multilateral framework agreement that provides a standardised and efficient mechanism to facilitate the automatic exchange of CbC Reports. The legal basis for the MCAA CbCR rests in Article 6 of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (“the Convention”) which provides for the Automatic Exchange of Information (“AEOI”) between parties to the Convention, where two parties subsequently agree to do so. More information on the MCAA CbCR, including the text of the MCAA, can be found on the OECD website. Please click here for more information.
  2. Why did Singapore sign the MCAA CbCR?

    The signing of the MCAA CbCR reaffirms Singapore’s commitment to the international standards on tax cooperation. The MCAA CbCR has gained recognition internationally as a multilateral framework agreement for bilateral cooperation on AEOI of CbC Reports, with 57 signatories as at 1 June 2017.

    Signing the MCAA CbCR will enable Singapore to efficiently establish a wide network of exchange relationships for the AEOI of CbC Reports. 
  3. Does signing the MCAA CbCR mean Singapore will exchange information with all MCAA signatories?

    No, signing the MCAA CbCR does not mean Singapore will automatically exchange CbC Reports with all the signatories.

    Under the MCAA, each signatory has ultimate control over exactly which exchange relationships it enters into and that each signatory’s standards on confidentiality, data protection and appropriate use of information will always apply. Singapore will establish bilateral AEOI relationships with fellow signatories that can meet the following principles:
     
    - The AEOI partner has the safeguards needed to ensure the confidentiality of information exchanged and prevent its unauthorized use; and

    - There is full reciprocity with the AEOI partner in terms of information exchanged.
  4. How will taxpayers know which jurisdictions have an effective exchange relationship with Singapore under the MCAA CbCR?

    The list of effective exchange relationships will be available on the OECD and IRAS website.

 

CbCR Filing Requirements

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 jurisdiction.

When CbC Report should be submitted

CbC Report should be submitted to IRAS within 12 months from the end of the ultimate parent entity's financial year.

  • Ultimate parent entity's FY ends in December:
    The first set of CbC Report will relate to the financial period 1 Jan 2017 to 31 Dec 2017 (FY 2017). This should be submitted to IRAS no later than 31 Dec 2018.
  • Ultimate parent entity's FY ends in March:
    The first set of CbC Report will relate to the financial period 1 Apr 2017 to 31 Mar 2018 (FY 2017). This should be submitted to IRAS no later than 31 Mar 2019.

Information to be Included in the CbC Report

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.

How to Submit the CbC Report

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.

Version  Status XML Schema User Guide
 1.0 * Current CbCR XML Schema
(OECD’s publication date: 22 March 2016)

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. The revised version will be uploaded as soon as OECD publishes it.

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.

Voluntary Filing (for FY 2016)

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.

Details of the mode of submission of your FY 2016 CbC Report will be released by the end of September 2017.

Penalties for Non-Compliance

If a company required to file the CbC Report fails to do so by the due date, IRAS may take the following actions:

  1. Impose a fine of up to $1,000
    If this fine is not paid, the person responsible for the offence may be imprisoned for up to six months.
  2. Impose a further fine of up to $50 for every day during which the offence continues after conviction.

A company which provides false or misleading CbC information may face the following consequences:

  1. A fine of up to $10,000; and/ or
  2. Person responsible for the offence may be imprisoned for up to two years.

For more details, please refer to our e-Tax guide on CbCR (440KB).

For enquiries, please email us at ct_transfer_pricing@iras.gov.sg.

RATE THIS PAGE

  • Strongly Disagree
  • Strongly Agree

Information is easy to understand.

Information is useful.

Information is easy to find.

Please email us if you would like us to respond to your enquiries.