CRS Registration Requirements
A failure to comply with this registration requirement is an offence under the CRS Regulations.
Reporting SGFIs are encouraged to apply for CRS registration as early as possible to avoid the last-minute rush.
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 (Cap 289) 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.
Who should register for CRS?
You are required to register for CRS if you are a custodial institution, a depository institution, an investment entity or a specified insurance company that is a:
- resident in Singapore, excluding its branch outside Singapore; or
- a Singapore branch of any financial institution not resident in Singapore
[Regulation 9 of the CRS regulations]
Types of Financial Institution under the CRS
Refer to Section 5 of the IRAS Common Reporting Standard e-Tax Guide (PDF, 896KB) for an overview of CRS Entity Classification
|Custodial Institution (Section 5.3 of e-Tax guide)
|A Custodial Institution is an Entity that holds, as a substantial portion of its business, Financial Assets for the account of others.
|Depository Institution (Section 5.4 of e-Tax Guide)
|A Depository Institution is an Entity that accepts deposits in the ordinary course of a banking or similar business.
|Investment Entity (Section 5.5 of e-Tax Guide)
|Type A – An Entity that primarily conducts as a business investment, activities or operations for or on behalf of other persons; or
Type B – An Entity that derives its gross income from investing, reinvesting, or trading in Financial Assets, and is managed by a FI (including a Type A Investment Entity).
|Specified Insurance Company (Section 5.11 of e-Tax Guide)
|A Specified Insurance Company is any Entity that is an insurance company (or the holding company of an insurance company) that issues, or is obligated to make payments with respect to a Cash Value Insurance Contract or an Annuity Contract.
Certain entities are not required to register for CRS. Please see below for some of the examples.
[Regulations 4-8, 10 and Part B of The Schedule of the CRS regulations]
Examples of entities that are not required to register for CRS
|Entities not required to register
|1. Non-Reporting SGFI that is:
|2. An Active or Passive Non-Financial Entity (NFE) that has no reporting obligation
|3. Investment entity that meets the “solely because” test because it only renders investment advice or manage portfolios for customers whose financial assets are deposited with another financial institution
|4. Trustee-documented trust (TDT) where the trustee of the trust is a Reporting SGFI and the trustee undertakes the CRS due diligence and reporting obligations of the trust
|5. Third-party service provider that is not a Reporting SGFI that assists Reporting SGFIs on their CRS obligations
What are the CRS Obligations of a Reporting SGFI?
As a Reporting SGFI, you are required to register for CRS, review the financial accounts that you maintain by applying CRS due diligence procedures to identify if the financial accounts are reportable accounts, and submit a CRS Return to IRAS to provide information on the reportable accounts on an annual basis. Please refer to CRS Filing for more details.
How to register for CRS?
Please have the following information ready before the application process:
- Singapore Tax Reference Number of the Reporting SGFI, if applicable.
- Singapore Tax Reference Number of the trustee if your financial institution is a Trust.
- Singapore Tax Reference Number of a Point of Contact if:
- your financial institution is not a Trust; or
- your financial institution is a Trust and has a Singapore non-individual Trustee.
Passport Number is required if the Point of Contact does not have a Singapore Tax Reference Number.
- Letter of Authorisation for the Point of Contact
There are two templates of Letter of Authorisation, please prepare and submit the appropriate letter accordingly:
Things to note:
- As the CRS and FATCA regulations share some similarities, you should also consider whether you are required to register for FATCA, and submit the registration application for FATCA if applicable. Please refer to FATCA Registration for more information.
- The First Year of Reporting is the year in which the entity is first determined as a Reporting SGFI for CRS purposes. For example, if the entity is first determined as a Reporting SGFI as at 31 December 2018, its First Reporting Year for CRS should be 2018, as that is the first calendar year in which the entity becomes a Reporting SGFI for CRS purposes and is subject to the reporting and due diligence requirements of CRS. In this regard, the applicant should indicate ‘2018’ in its CRS application. For details on filing CRS returns, please refer to CRS Filing .
- If you are late in your application for CRS registration (e.g. you submitted your registration as a Reporting SGFI in 2020 but you met the requirements of a Reporting SGFI in 2018), then upon approval of your application, you are required to submit the CRS Returns from 2018 (i.e. First Year of Reporting) to the latest Reporting Year. For details on filing back-year CRS returns, please refer to CRS Filing .
The average processing time for the registration application is expected to be 3 weeks. Once the application is processed, an e-mail will be sent to the Point of Contact or individual trustee to inform him/her on the registration outcome.
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
Qualifying PICs would be required to file its CRS return annually using the simplified AEOI registration and reporting form.
How to notify IRAS of a Trustee-Documented Trust (TDT)?
A Trustee-Documented Trust qualifies as a Non-Reporting FI because the trustee of the trust is a Reporting SGFI and the trustee undertakes the due diligence and reporting obligations of the trust. A TDT need not apply to register with IRAS for CRS purposes.
The trustee of a TDT has to provide certain details on the TDT such as its name and Tax Reference Number, if applicable, to IRAS before the trustee can submit a CRS Return on the trust’s behalf.
How to update Point of Contact?
You should periodically review your POC and update IRAS as soon as possible on changes in the POC so that you will receive prompt notification on your CRS matters.
Please prepare and submit the appropriate letter accordingly:
Who should deregister for CRS?
You should deregister for CRS as soon as applicable if you are:
- in the process of liquidation or has been liquidated;
- preparing to strike-off the entity with ACRA or already struck-off by ACRA;
- no longer a Reporting SGFI (e.g. due to update of status to an Active or Passive Non-Financial Entity (NFE), cessation of Capital Markets Services (CMS) license issued by the Monetary Authority of Singapore, etc.); or
- no longer a tax resident of Singapore.
Things to note:
- As the CRS and FATCA regulations share some similarities, for Reporting SGFIs that are also registered for FATCA, please note that you should also consider whether you are required to deregister for FATCA, and submit the deregistration application for FATCA if applicable. Please refer to FATCA Deregistration for more information.
- You should submit your final CRS return and any outstanding CRS returns and ensure that the returns are accepted before you submit an application to deregister the entity.
How to deregister for CRS?
You can submit your deregistration application via myTax Portal > Select More > AEOI > Apply to Deregister for AEOI e-Service.
A third-party service provider of the Reporting SGFI will not be able to access the deregistration e-Service.
We strongly encourage you to submit the deregistration application online before the entity becomes inactive (e.g. liquidated or struck-off).
Step-by-step guide on deregistration via myTax Portal
Step 1: File your final and outstanding CRS Returns
Prior to deregistration, you should ensure that there are no outstanding CRS Returns. You should also make an advance filing to report any Reportable Accounts in the year of liquidation or cessation of activities that qualify the entity as a Reporting SGFI. For example, if the entity is closing or no longer a Reporting SGFI in 2021, it should report a final return for Reporting Year 2021 as it is the year it ceases to be a Reporting SGFI. If there is no reportable account to file, you should submit a Nil return.
You can submit an advance filing (e.g. filing for Reporting Year 2021 in the year 2021) at myTax Portal > Select More > AEOI > Submit CRS or FATCA Return select ‘Advance Reporting Year’. Refer to CRS Filing for more details on the filing requirements and process.
Once you have received confirmation that the CRS Returns have been accepted, you can submit the deregistration application via myTax Portal > Select More > AEOI > Apply to Deregister for AEOI e-Service.
Note that third-party service provider of the Reporting SGFI will not be able to access the deregistration e-Service.
Step 2: Prepare documents required for deregistration
Please have the following documents ready for the deregistration:
- Cover letter (printed on company’s letterhead) containing the following:
- entity name and Tax Reference Number;
- reason for the deregistration;
- new entity classification (e.g. Active or Passive NFE), if applicable;
- the date in which the entity ceases to be a Reporting SGFI or dates of the impending liquidation/struck-off, if available; and
- signature of the director
Please refer to the Sample Cover Letter for Deregistration (DOC, 29KB).
- Supporting documents, if applicable, such as:
- communication from MAS confirming the cessation of the CMS license;
- communication confirming the entity is preparing for liquidation or in the process of liquidation and struck-off; or
- documentary evidence confirming that the entity is not a tax resident of Singapore
- As you can only upload 1 document on the e-Service, please combine all the documents in one PDF file for uploading (note: maximum file size allowed 2MB)
Step 3: Submit deregistration application
Submit the deregistration application via myTax Portal > Select More > AEOI > Apply to Deregister for AEOI e-Service.
For more information, you may refer to the Apply to Deregister for AEOI e-SvcUser Guide (PDF, 338KB).
The average processing time for the deregistration application is expected to be 3 weeks. IRAS will process your application and may contact you for more information. Once the application is processed, a notice will be available on myTax Portal to inform him/her on the deregistration outcome.
If your entity has been dissolved or struck-off and is no longer able to access myTax Portal, you should follow the steps below and e-mail [email protected] with the following information and supporting documents.
Information and supporting documents required
Step 1: File your final and outstanding CRS Returns
Prior to deregistration, you should ensure that there are no outstanding CRS returns. You should also make an advance filing to report any Reportable Accounts in the year of liquidation or cessation of activities that qualify the entity as a Reporting SGFI. For example, if the entity has been liquidated or struck-off in the year 2021, it should report a final return for Reporting Year 2021 as it is the year it ceases to be a Reporting SGFI. If there is no reportable account to file, you should submit a Nil return.
As the CRS returns must be filed via myTax Portal, the appointed liquidator will need to request access to myTax Portal on your behalf via Corppass. Please refer to the step-by-step guide on how liquidators can access the AEOI e-Services on behalf of the liquidated entity via Corppass (PDF, 2,072KB).
To submit an advance filing (e.g. filing for Reporting Year 2021 in the year 2021), go to myTax Portal > Select More > AEOI > Submit CRS or FATCA Return and select ‘Advance Reporting Year’. Refer to CRS Filing for more details on the filing requirements and process.
Step 2: Submit deregistration application via e-mail
Once the CRS Returns have been accepted, either you or the liquidator can submit the deregistration application via e-mail to [email protected].
In your e-mail:
- indicate the Tax Reference Number, Entity name and the date of liquidation or struck-off.
- inform IRAS on the successfully filing of reportable financial accounts which are to be reported for the relevant reporting years or Nil returns (e.g. in the year of liquidation and back years, if any)
- attach the supporting documents such as:
- Latest ACRA business profile;
- ACRA gazette; and
- Notice of appointment of liquidator
Please refer to the Sample Cover Letter for Deregistration (DOC, 29KB).
How do trustees end-date the CRS reporting of a Trustee-Documented Trust (TDT)?
The trustee can terminate a TDT if it no longer manages it. The trustee can terminate by end-dating it via myTax Portal.
You should ensure that there are no outstanding CRS returns before end-dating the reporting of a TDT.