Common Reporting Standard ("CRS")

Date
What's new 
25 April 2018

Reporting SGFIs may start submitting their CRS returns for Reporting Year 2017.

More information can be found here

25 April 2018 A Quick Guide to CRS Return Submission has been prepared for Reporting SGFIs to get instructions on how to submit their CRS returns.  
9 April 2018 OECD CRS Implementation Handbook - 2nd edition of the Handbook has been published 
9 April 2018 List of Reportable Jurisdictions for 2017 CRS reporting updated: Reporting SGFIs are to submit CRS information for the new jurisdictions added to the list by 31 August 2018. 
21 March 2018

Part B of the XML Schema User Guide has been updated.

The list of IRAS' CRS File and Record Level Errors is available here.  

27 February 2018 Notice issued to Financial Institutions on CRS Registration - IRAS has issued a notice to all FIs in Singapore reminding them of the CRS registration obligation. 
27 February 2018 A Quick Guide to CRS Registration has been prepared for entities to check if they are required to register and to get instructions on how to register. 
13 February 2018 

Reporting SGFIs can now authorize their staff and/or Third Party to access the new AEOI e-Services. A Quick Guide to the newly launched e-Services can be found here.

More information on the AEOI e-Services can be found here.

The "Submit CRS Return" module for Reporting SGFIs to submit their CRS Returns for Reporting Year 2017 will be launched in the second half of April 2018 (updated on 21 March 2018). 

Past updates can be found here.


Background

Automatic exchange of information (“AEOI”) based on the CRS refers to the regular exchange of financial account information between jurisdictions for tax purposes, with the objective of detecting and deterring tax evasion by taxpayers through the use of offshore bank accounts.

The CRS is an internationally agreed standard for AEOI on financial account information, endorsed by the OECD and the Global Forum for Transparency and Exchange of Information for Tax Purposes. The CRS sets out the financial account information to be exchanged, the financial institutions (“FIs”) required to report, the different types of accounts and taxpayers covered, as well as the customer due diligence procedures to be followed by FIs. The CRS builds on the FATCA reporting regime to maximise efficiency and reduce costs for implementing jurisdictions and their FIs. More than 100 jurisdictions, including major financial centres such as Dubai, Hong Kong, Luxembourg and Switzerland, have endorsed the CRS and will commence AEOI in either 2017 or 2018.

Singapore has committed to implement the CRS, with the first exchange to take place by September 2018. 

More information on the CRS can be found here.

Competent Authority Agreement ("CAA")
A CAA enables the implementation of the information exchange based on existing legal instruments such as a tax information exchange agreement, a bilateral tax treaty or the Convention on Mutual Administrative Assistance in Tax Matters ("the Convention").

A CAA is either a bilateral or multilateral agreement that sets out the type of information to be exchanged between two jurisdictions, the time and manner of exchange as well as the confidentiality and data safeguards to be respected for the exchange of information. More information on the bilateral CAAs signed and activated exchange relationships under the multilateral CAA is available here.

CRS Regulations
The Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) Regulations 2016 (“CRS Regulations”) incorporate the requirements of the CRS into Singapore’s domestic legislative framework. The CRS Regulations has entered into force on 1 January 2017.
     •  CRS Regulations

The CRS Regulations requires and empowers all FIs to put in place necessary processes and systems to collect financial account information from 1 January 2017. Singapore has adopted the “wider approach”, which means that FIs will need to collect and retain the CRS information for all account holders and where the account holder is a Passive Non-Financial Entity ("NFE"), the controlling persons of the Passive NFE in the case of new accounts, instead of only for account holders and controlling persons who are tax residents of Singapore’s CAA partners. For CRS reporting purposes, SGFIs will need to transmit to IRAS the financial account information relating to tax residents of Singapore’s CAA partners from 2018. IRAS will subsequently exchange the reported information with Singapore’s CAA partners.


List of Reportable Jurisdictions

Under the CRS Regulations, Reporting SGFIs are required to provide IRAS with a return setting out the CRS information of Reportable Accounts that they maintained during the calendar year. Every Reporting SGFI that maintains Financial Accounts that are not Reportable Accounts is required to file a nil return with IRAS for the relevant reporting year. Reportable Accounts are Financial Accounts that are held by Account Holders and where the Account Holder is a Passive NFE, the Controlling Persons of the Passive NFE that are tax residents of a Reportable Jurisdiction.


The updated list of Reportable Jurisdictions for 2017 CRS information reporting is available here. Reporting SGFIs are required to submit 2017 CRS information, including nil returns (if applicable), by 31 May 2018, or in respect of the two new jurisdictions added (China and Malaysia), by 31 August 2018.   

List of Participating Jurisdictions
Under the CRS, a Reporting SGFI which maintains an account for a professionally managed Investment Entity (as described in sub-paragraph A(6)(b) of Section VIII of the CRS), that is not a Participating Jurisdiction FI, has to treat the Investment Entity as a Passive NFE and apply the "look through" to identify the Controlling Persons.


In line with the approach that is outlined in paragraph 31 of the CRS Implementation Handbook, Singapore will consider all jurisdictions that have publicly and at government level committed to adopt the CRS as Participating Jurisdictions. The list of Participating Jurisdictions will be updated at least once a year to reflect changes in jurisdictions' commitment to and implementation of the CRS, and will be published on IRAS' CRS webpage.

This list of Participating Jurisdictions is available here.
 
CRS Guidance
In implementing the CRS, SGFIs may rely on the following materials for interpretive guidance.

IRAS-issued guidance comprising FAQs and basic guides on CRS to help financial institutions, service providers and account holders understand the key requirements of the CRS and how they will be affected by its implementation:
    •  IRAS FAQs (updated on 12 January 2018)
     •  How account holders of FIs will be affected 

     • IRAS CRS brochure for account holders  


Draft IRAS CRS e-Tax Guide on the Common Reporting Standard

The draft IRAS CRS e-Tax Guide is intended to assist businesses and those affected by CRS, in particular SGFIs, in understanding the CRS framework and their CRS compliance obligations. A public consultation was held from 25 August to 25 September 2017. We are reviewing the feedback received and will publish the finalised Guide on this page.

OECD-issued guidance
     •  Commentaries on the CRS
     •  CRS Implementation Handbook  (2nd edition)
     •  CRS-related FAQs (updated in December 2017)

CRS Registration

An entity that is or becomes a Reporting SGFI at any time between 1 January 2017 and 31 December 2017 (both dates inclusive) must apply for CRS Registration by 31 March 2018. A failure to comply with the registration requirement is an offence under the CRS Regulations.

Certain groups of Reporting SGFIs need not register with IRAS for CRS purposes. For more details on CRS registration requirements, please refer to the following:

The application for CRS registration will take about 3 weeks to be processed. Once the application is processed, we will send an email to the Point of Contact or individual trustee to inform him/her of the registration outcome. 

Reporting SGFIs can also check on their CRS registration status using the Check CRS Registration Status e-Service.

AEOI e-Services 

The following AEOI e-Services are now available:

  • View/ Update FI AEOI Profile

  • View / Update My Profile

  • View AEOI Contact Details

  • View / Edit Trustee-Documented Trusts

  • View AEOI e-Service Transaction History

  • View Submitted Financial Account Report

  • View AEOI Notices / Letters

  • Email Us on AEOI matters using myTax Mail

  • Apply to Deregister for AEOI

  • Submit CRS ReturnNew!

Reporting SGFIs that have registered for CRS can authorise their staff and/or Third Party via the e-Services Authorisation System (EASY) to access these new e-Services. A Quick Guide to the AEOI e-Services can be found here.

More information on the AEOI e-Services can be found here.

CRS Filing Requirements

Reporting SGFIs may start submitting their CRS returns for Reporting Year 2017. All CRS returns, including nil returns (if applicable), must be submitted electronically to IRAS via the "Submit CRS Return" e-Service. No paper returns will be accepted. A simplified process for submitting nil returns electronically is available via this e-Service.

A Quick Guide to CRS Return Submission has been prepared for Reporting SGFIs to get instructions on how to submit their CRS returns.

Reporting SGFIs can submit their CRS returns using fillable PDF forms, if they do not wish to acquire a reporting tool to generate the CRS returns in XML format. Each fillable PDF form can however accommodate up to 40 account reports only. If more than one such form is used, each form must be submitted individually via the e-Service. The fillable PDF form is available here.

    CRS Data Format
    Reporting SGFIs will need to have processes in place to collate and prepare the required data in accordance with the prevailing CRS XML Schema and XML Schema User Guide set out in the table below. 

    XML Schema User Guide
    CRS XML Schema v1.0 

    IRAS XML Schema User Guide for CRS Return (Second Edition)
    (Published on 21 March 2018) 

    When a Reporting SGFI receives a notification from IRAS to inform that the Reporting SGFI's submitted CRS Return has been i) rejected or ii) accepted with record level errors, the Reporting SGFI should refer to the List of IRAS CRS File and Record Level Errors for more information on the identified error(s) and the necessary resolution(s).

    Subscribe to IRAS eAlerts
    You can subscribe to IRAS eAlerts so that you will be informed when there are updates to the IRAS CRS webpage.