CRS Filing Requirements
Under the CRS Regulations, a Reporting SGFI is required to submit annual CRS return(s) to IRAS setting out the required information in relation to every Reportable Account that is maintained by the SGFI. Reporting SGFIs that did not maintain any Reportable Accounts in the relevant reporting year are required to file a nil return to IRAS.
Due Date for Filing
Example on deadline to register and submit CRS return
Company A was incorporated in Mar 2019. In Feb 2020, the company obtained the Capital Markets Service (CMS) licence under the Securities and Futures Act 2001 from MAS and became a Reporting SGFI as it has met its definition of an investment entity under Regulation 7(1)(a) of the CRS Regulations. Company A is required to register for CRS with IRAS before 31 Mar 2021 and needs to submit its CRS return for its first Reporting Year 2020 to IRAS by 31 May 2021.
Penalties for Late Filing NEW
Reporting SGFIs may face enforcement actions, including a penalty of up to $5,000, for late or non-filing of their CRS returns.
Requesting for Filing Extensions NEW
All Reporting SGFIs need to plan their resources to submit their CRS returns on time.
No extensions will be granted, except for newly registered Reporting SGFIs and for circumstances that fall within the list of acceptable reasons below.
|S/N||Acceptable Reasons||Maximum extension granted|
|1||Newly registered Reporting SGFI (1st return)||1 month|
|2||Breakdown of IT system or Change of IT software/ system||2 weeks|
|3||Key personnel handling CRS filing is on unexpected long medical leave||2 weeks|
No extensions will be granted for the following reasons.
|S/N||Reasons that are not acceptable|
|1||Not enough manpower to handle CRS matters|
|2||Key personnel overseas or resigned without proper handover|
|3||New staff does not know how to handle CRS matters|
Simplified CRS Registration and Filing Requirements for Qualifying Personal Investment Companies (PICs)
PICs that are liable to register for CRS and have reporting obligations should file their annual returns via myTax Portal. However, a Qualifying PIC, that is, a PIC that does not have a tax reference number (e.g. UEN, ASGD or ITR Number) and meets all the following criteria below may qualify for simplified CRS registration and reporting requirements:
- the PIC is incorporated overseas and is a tax resident in Singapore;
- the PIC qualifies for S13F and S13N exemptions under the Income Tax Act 1947;
- the PIC is 100% owned by a SGFI; and
- the PIC does not maintain any reportable accounts as defined in the CRS Regulations
How to submit a CRS return NEW
From 11 Apr 2021, you will be required to log in to government digital services for businesses (G2B) using Singpass instead of Corppass. For more information, visit Corppass website.
Step 1: Authorise users for CRS Filing
Before filing the CRS returns, please ensure that you have been authorised by the Reporting SGFI as an “Approver” for Automatic Exchange of Information (CRS and FATCA) e-Service in Corppass. For assistance on Corppass setup, please refer to the step-by-step guides.
Step 2: Submit CRS return on myTax Portal
Once you are authorised for AEOI e-Services, use your Singpass to log in to myTax Portal > Select More > AEOI > Submit CRS or FATCA Return. Please ensure that you have the following information on hand before submission:
- Your Singpass;
- The Reporting SGFI's Singapore Tax Reference Number (e.g. UEN, ASGN or ITR); and
- CRS returns (where applicable) (maximum files size 5MB)
For more information on how to submit a CRS return on myTax Portal, you may refer to the Submit CRS or FATCA Return e-Service User Guide (PDF, 454KB).
CRS Submission Format
|XML Format||Fillable PDF Form|
|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.|
IRAS XML Schema User Guide for CRS Return (Third Edition) (PDF, 4,4440KB)
|Alternatively, Reporting SGFIs can submit their CRS returns using the fillable PDF form version 2.0 (PDF, 3,490KB), if they do not wish to acquire a reporting tool to generate the CRS returns in XML
format. Each PDF form can 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. |
Reporting SGFIs can select the option “Return with Nil Data” within “Submit CRS or FATCA Return" e-Service if they did not maintain any reportable accounts in the reporting year.
CRS Submission Status and Return Errors
|CRS return is accepted||CRS return is accepted with record-level error(s) or rejected|
|You should receive the notice, “Notification of Acceptance of AEOI Return” in myTax Portal > Select Notice/Letters > AEOI. |
No further action is required from you.
|You should receive the notice, “Notice of AEOI Return Error” in myTax Portal > Select Notice/Letters > AEOI. |
If your return status is “Accepted with record-level error(s)”, please review the error(s) and correct or void the erroneous record(s) by submitting a “Correction CRS Return”.
If your return status is “Rejected”, please rectify the error(s) and resubmit the CRS return with a different MessageRefID. Please resubmit the CRS return to IRAS as a “Return with New Data”.
How to rectify the errors in CRS return?
The Notice of AEOI Return Error will list the specific record that contains an error and the error code. Please refer to the IRAS CRS File and Record Level Validations (PDF, 215KB) for more information on the identified error(s) and the necessary resolution(s).
List of Common CRS Return Errors
|S/N||Error Code||Error Description||What you need to do?|
|1||50005/ 50006||The system detected one or more known viruses, threats within the CRS return |
|2||50007||The CRS return failed validation against the CRS XML Schema|
|3||60011||The ResCountryCode of the Individual does not match the Country Code of a Reportable Jurisdiction.|
|4||60012||The ResCountryCode of the Entity does not match the Country Code of a Reportable Jurisdiction.|
|5||80001||The structure of the DocRefID is not in the correct format as set out in the IRAS XML Schema User Guide.|
Please refer to the List of IRAS CRS File and Record Level Errors (PDF, 215KB) for the full list of CRS return errors and the necessary resolution(s).
List of Reportable Jurisdictions
Why do I need to know the 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.
Please refer to the List of Reportable Jurisdictions (PDF, 136KB) for 2021 CRS information reporting.
List of Participating Jurisdictions
Why do I need to know the list of Participating Jurisdictions?
Under the CRS Regulations, 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 (PDF, 146KB) 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.