Common Reporting Standard

The Common Reporting Standard (CRS) is an internationally agreed standard for the automatic exchange of financial account information between jurisdictions for tax purposes, to better combat tax evasion and ensure tax compliance.

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 have commenced AEOI in either 2017 or 2018. 

Singapore has committed to implement the CRS and the first exchange took place in September 2018. 

More information on the CRS can be found here.

 

What's New

Date What's new 
23 July 2019

New CRS Compliance section published.

More information is available here.

23 July 2019

First edition of CRS Compliance Guidelines e-Tax Guide published.

The IRAS CRS Compliance Guidelines e-Tax Guide is available here (1,145KB).

23 July 2019

First edition of CRS e-Tax Guide published.

The IRAS CRS e-Tax Guide is available here (1702KB).

22 April 2019 

Reporting SGFIs may start submitting their CRS returns for Reporting Year 2018.

More information can be found here
22 April 2019 IRAS CRS FAQs (899KB) document updated: updates were made to FAQs C.6, G.1 and G.2, and a new FAQ F.10 was added. 
22 April 2019 IRAS CRS Registration FAQs (601KB) document updated: updates were made to FAQs 7, 8 and 15.  
20 March 2019 Entities can use the CRS Entity Classification self-review tool (191KB) to determine their CRS entity classification, and check if they are required to register for CRS.  

 Past updates can be found here.

CRS Registration

Register for CRS via the Apply for CRS Registration e-service.

An entity that becomes a Reporting SGFI between 1 January and 31 December (both dates inclusive) of the year is to register for CRS by 31 March of the following year. A failure to comply with this registration requirement is an offence under the CRS Regulations.

The CRS registration deadline for an entity that became a Reporting SGFI between 1 January 2018 and 31 December 2018 (both dates inclusive) is 31 March 2019.  All entities that became Reporting SGFIs during this period are to register for CRS with IRAS by the deadline.

Certain groups of Reporting SGFIs need not register with IRAS for CRS purposes. Entities can use the CRS Entity Classification self-review tool (191KB) to determine their CRS entity classification and check if they are required to register for CRS.

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 on the registration outcome. 

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

 

CRS Filing

For Reporting SGFIs to submit their annual CRS returns, log in to myTax Portal, select More > AEOI > Submit CRS Return.

All Reporting SGFIs must submit their CRS returns, including nil returns (if applicable) for a reporting year by 31 May of the following year. The CRS returns 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 (460KB) 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 (222KB). 

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 SchemaUser 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 (497KB) for more information on the identified error(s) and the necessary resolution(s).

A Reporting SGFI will receive a notification from IRAS to inform that the submitted CRS Return has been accepted by IRAS, if the submitted CRS Return does not have either file or record level errors. 

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 list of Reportable Jurisdictions for 2018 CRS information reporting is available here (483KB). Reporting SGFIs are required to submit 2018 CRS information, including nil returns (if applicable), by 31 May 2019.  

 

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 (352KB).  

   

CRS Compliance

Financial institutions are required to comply with the CRS Regulations in Singapore. In particular, Reporting Singaporean Financial Institutions (“Reporting SGFIs”) under the CRS Regulations must:

  • Register for CRS with IRAS;
  • Perform due diligence on all Financial Accounts that it maintains; and
  • Report all Reportable Accounts that it maintains or file a Nil Return (if it does not maintain any Reportable Accounts) to IRAS.

IRAS expects Reporting SGFIs to put in place a robust compliance approach as well as internal policies, procedures and systems that will ensure their effective compliance with the CRS in Singapore.

IRAS will work with and assist Reporting SGFIs that are voluntarily compliant to ensure their compliance with CRS in Singapore. On the other hand, IRAS will not hesitate to take deterrent measures such as issuing warnings and imposing penalties on errant Reporting SGFIs that choose to be non-compliant.

To assist Reporting SGFIs in complying with the CRS requirements in Singapore, IRAS has issued a CRS Compliance Guidelines e-Tax Guide (1,145KB). The e-Tax Guide describes IRAS’ guiding principles and compliance activities when reviewing whether Reporting SGFIs are fulfilling their CRS obligations effectively. It also explains IRAS’ expectations on the approach that Reporting SGFIs should take when demonstrating their compliance with CRS in Singapore.

As Reporting SGFIs are expected to put in place a set of CRS internal controls to manage their CRS regulatory risks, IRAS has established 23 hallmarks or desired outcomes that Reporting SGFIs should achieve to demonstrate the sufficiency and robustness of the Reporting SGFI’s operating environment, how it fulfils its CRS due diligence obligations and the manner in which the Reporting SGFI fulfils its CRS reporting obligations.

In addition, to assist Reporting SGFIs in meeting the hallmarks or desired outcomes, IRAS has designed a self-review toolkit containing recommended internal controls that a Reporting SGFI may implement. The self-review toolkit can be found in Annex A of the e-Tax Guide. 

   

IRAS takes a risk-based approach to ensure that Reporting SGFIs comply with their CRS obligations in Singapore. IRAS also seeks to minimise Reporting SGFIs’ compliance costs while ensuring their CRS compliance.

In assessing the risk of non-compliance by Reporting SGFIs, IRAS will consider, among others, a combination of factors such as:

  • Business profile and activities of the Reporting SGFI;
  • Track record in fulfilling its FATCA and CRS obligations;
  • Track record in other relevant areas of tax and regulatory compliance; and
  • Feedback received from Singapore’s CRS partners. 
     

IRAS will conduct desk-based and/or on-site reviews on Reporting SGFIs that pose a higher risk of non-compliance with the CRS. Depending on IRAS’ assessment of how effectively the identified Reporting SGFI has fulfilled its CRS obligations in Singapore, IRAS may issue recommendations for the Reporting SGFI to address gaps in its CRS compliance and undertake timely corrective actions.

IRAS will also approach entities which are not registered as Reporting SGFIs to verify their entity classification under the CRS.

Any person who fails to comply with the CRS obligations shall be guilty of an offence under Section 105M of the Income Tax Act (“ITA”).

Any person who produces to IRAS any document which contains any information, or provides to IRAS any information, known to the person to be false or misleading shall also be guilty of an offence under the same Section.

If any person enters into an arrangement or takes an action in order to avoid any obligation under the CRS, IRAS may disregard the arrangement or action under Section 105MA of the ITA, and the appropriate CRS obligation shall then apply accordingly.

If you are aware of any potential CRS non-compliance through the use of schemes, products and/or structures to circumvent reporting under the CRS, you may provide information to the IRAS here.

 

CRS Resources - Legislation, Guidance and References

CRS Legislation

The legislative provisions to implement the CRS are set out at Part XXB of the Income Tax Act (Cap. 134) and the Income Tax (International Tax Compliance Agreements)(Common Reporting Standard) Regulations 2016 ("CRS Regulations").

Part XXB of the Income Tax Act (Cap. 134) contains the enabling provisions to implement the CRS in Singapore.

The CRS Regulations incorporate the requirements of the CRS into Singapore’s domestic legislative framework. The CRS Regulations entered into force on 1 January 2017. 

 The CRS Regulations requires and empowers all FIs to 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 NFE, the controlling persons of the Passive NFE in the case of new accounts, instead of only for account holders and controlling persons that 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.


CRS Guidance

In implementing the CRS, SGFIs may rely on the following materials for interpretive guidance.


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.

On 21 June 2017, Singapore signed the CRS MCAA. The signing of the CRS MCAA will enable Singapore to efficiently establish a wide network of exchange relationships for the automatic exchange of information based on the CRS. For more details, the press release is available here.

The CRS MCAA is a multilateral framework agreement based on the Convention. It provides a standardised and efficient mechanism to facilitate the automatic exchange of information based on the CRS. Under the CRS MCAA, a bilateral exchange relationship comes into effect only if (i) both jurisdictions are signatories to the CRS MCAA, (ii) have filed the relevant notifications under Section 7 of the CRS MCAA, and (iii) have listed each other as intended exchange partner jurisdictions under the CRS MCAA. Please refer to the OECD webpage for the full list of partners from whom Singapore will receive CRS information.

Singapore is engaging in automatic exchange of information based on the CRS under the following bilateral CAAs:

Jurisdiction First Reporting Year1Date of Signing Date of Entry into Force2First Submission from SGFIs by
(First Exchange by)
Denmark201713 March 20175 June 2017

31 May 2018

(September 2018)

Finland2017 22 November 201631 January 2017 31 May 2018
(September 2018)
Iceland2017 13 December 201631 January 2017 31 May 2018
(September 2018) 
Ireland2017 20 December 201631 January 2017 31 May 2018
(September 2018)
Japan2017 13 October 201631 January 2017 31 May 2018
(September 2018) 
Latvia2017 20 December 2016 27 February 2017 31 May 2018
(September 2018) 
Lithuania2017 23 February 2017 5 June 201731 May 2018
(September 2018) 
Malta2017 15 December 2016 31 January 2017 31 May 2018
(September 2018) 
Norway2017 25 October 201631 January 2017 31 May 2018
(September 2018) 
South Africa2017 24 October 201631 January 2017 31 May 2018
(September 2018)
United Kingdom     201716 September 201631 January 2017 31 May 2018
(September 2018)
Switzerland201817 July 20171 August 2019 31 May 2019
(September 2019)

 

1This refers to the first calendar year to which information of a reportable account maintained by a Reporting SGFI relates and has to be reported to IRAS for exchange with Singapore’s AEOI partners.
2A jurisdiction becomes a "Reportable Jurisdiction" after the CAA for CRS between Singapore and that jurisdiction has entered into force.

AEOI e-Services

You can access the AEOI e-Services via these 3 steps:

Step 1: Register as a Reporting SGFI

Step 2: Authorise FI users and third parties via CorpPass

Step 3: Log in to myTax Portal to access the AEOI e-Services

The following AEOI e-Services are 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 Return

Reporting SGFIs that have registered for CRS can authorise their staff and/or Third Party via  CorpPass to access these 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.

 

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.

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