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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.

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Qualifying Competent Authority Agreement

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. At the present time, not all the signatories to the MCAA have provided full or complete notifications of their intended exchange relationships. Some jurisdictions may also increase their exchange relationships over time. The list of exchange relationships below is therefore not the final list of exchange relationships that Singapore will enter into. For more information, please visit the OECD webpage.

Updated! List of jurisdictions
 Jurisdictions Exchange relationship effective from
1. ArgentinaFY2017 
2. Australia FY2016 
3. Austria FY2017 
4. Belgium FY2016
5. Bermuda FY2017 
6. BrazilFY2016 
7. Bulgaria FY2016 
8. Canada FY2017 
9. Cayman Islands FY2016
10. Chile FY2017 
11. ChinaFY2017 
12. Colombia FY2016 
13. Costa RicaFY2017
14. Croatia FY2017 
15. CuracaoFY2018 
16. Cyprus FY2017 
17. Czech Republic FY2017 
18. DenmarkFY2016 
19. Estonia FY2017 
20. Finland FY2016 
21. France FY2016 
22. Germany FY2016 
23. Greece FY2016 
24. Guernsey FY2016 
25. HungaryFY2017
26. IcelandFY2017
27. India FY2016 
28. Indonesia FY2017 
29. Ireland FY2016 
30. Isle of ManFY2017
31. Italy FY2016 
32. Japan FY2016 
33. Jersey FY2016 
34. Korea FY2016 
35. Latvia FY2017 
36. LiechtensteinFY2017
37. Lithuania FY2016 
38. Luxembourg FY2016 
39. MalaysiaFY2017
40. MaltaFY2016 
41. MauritiusFY2018
42. Mexico FY2016 
43. Netherlands FY2016 
44. New Zealand FY2016 
45. Nigeria FY2018 
46. Norway FY2016 
47. Pakistan FY2016
48. Poland FY2016 
49. Portugal FY2017 
50. Qatar FY2020 
51. Romania FY2016
52. RussiaFY2017
53. Slovak Republic FY2016 
54. Slovenia FY2016 
55. South Africa FY2016 
56. Spain FY2016 
57. Sweden FY2016 
58. Switzerland FY2018
59. United Kingdom FY2016 
60. Uruguay FY2017

Updated as at 16 Nov 2018.

FAQs
  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 is available on the OECD and IRAS website.

 

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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.

Examples
  • 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. Please refer to the e-Tax Guide (712KB) for details on the report format and information to be submitted.

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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
1.0.1 CurrentCbCR XML Schema v1.0.1
(OECD’s publication date: 20 Sep 2017)

CbCR XML Schema User Guide for Tax Administrations
(For CbCR XML Schema version 1.0.1. OECD’s publication date: 20 Sep 2017)

Revised! IRAS’ Supplementary Instructions for Preparing CbCR Reporting Data File 
(Updated for CbCR XML Schema version 1.0.1)

 

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Filing CbC Report for FY 2017

FY 2017 refers to FYs beginning on or after 1 Jan 2017 but before 1 Jan 2018. 

IRAS has sent letters to Reporting Entities notifying them of their obligation to file a CbC Report for FY 2017. If you are required to file a CbC report based on the conditions (in paragraph  “CbCR Filing Requirements” above) but have not received IRAS’ letter by 31 July 2018, please contact IRAS immediately by emailing to ct_transfer_pricing@iras.gov.sg.

Reporting Entities who are required to file a CbC report must provide IRAS with the following information at least 3 months before the filing deadline by emailing to ct_transfer_pricing@iras.gov.sg: 

  • Name and UEN of the UPE (i.e. Reporting Entity);
  • Financial reporting period of the UPE (DD/MM/YYYY to DD/MM/YYYY); 
  • Contact person’s name and contact number;
  • Email of contact person (if different from that used to provide your reply).

Reporting entities must submit their FY 2017 XML CbC reports via email to ct_transfer_pricing@iras.gov.sg with the following details:

  • Name of the UPE (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 authorised via EASY.

The XML CbC report must be zipped (file extension must be in zip format *.zip) and password-protected^, with the Reporting Entity's name as the name of the file (e.g. ABC Ltd.zip). After you have emailed your CbC report, please call 6351 2609 (Mondays to Fridays, 8 am to 5 pm) to provide us the password to open the report.

^Note: Please use a strong password. It is recommended that the password should be:
- At least eight characters; and  
- Alphanumeric with at least one upper and lower case alphabet, number and symbol (e.g. Pj57#uEw). 

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Penalties for Non-Compliance

Late Filing or Failing to File CbC Report

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.
False/ Misleading CbC Information

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 (712KB).

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

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