Singapore-headquartered multinational enterprise (MNE) groups meeting certain requirements are required to prepare and file CbC Reports to IRAS for financial years (FYs) beginning on or after 1 Jan 2017 within 12 months from the end of their FY.

New! For FY beginning on or after 1 Jan 2022, these Singapore MNE groups are also required to notify IRAS of their obligation to file a CbC Report, within 3 months from the end of that relevant FY.

What is CbCR?

CbCR is a form of reporting by 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 requirements must prepare and file CbC Reports to IRAS for FYs beginning on or after 1 Jan 2017.

Qualifying Competent Authority Agreement

On 21 Jun 2017, Singapore signed the Multilateral Competent Authority Agreement on the exchange of CbC Reports (CbC MCAA). The signing of the CbC MCAA will enable Singapore to efficiently establish a wide network of exchange relationships for the automatic exchange of CbC Reports. View the press release.

The CbC MCAA 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 CbC MCAA, 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 Automatic Exchange of Information (AEOI) relationships under the MCAA. At the present time, not all 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.

List of Jurisdictions

 Jurisdiction Exchange relationship effective from
1. Andorra FY 2018
2. AnguillaFY 2019
3. ArgentinaFY 2017 
4. Australia FY 2016 
5. Austria FY beginning 1 June 2016 
6. AzerbaijanFY 2020
7. BahamasFY 2019 
8. BahrainFY 2021 
9. Belgium FY 2016
10. BelizeFY 2019 
11. Bermuda FY 2017 
12. BrazilFY 2016 
13. British Virgin IslandsFY 2018
14. Bulgaria FY 2016 
15. Canada FY 2017 
16. Cayman Islands FY 2016
17. Chile FY 2017 
18. ChinaFY 2017 
19. Colombia FY 2016 
20. Costa RicaFY 2017
21. Croatia FY 2017 
22. CuracaoFY 2018 
23. Cyprus FY 2017 
24. Czech Republic FY beginning 1 October 2016 
25. DenmarkFY 2016 
26. Estonia FY beginning 1 August 2016 
27. Finland FY 2016 
28. France FY 2016 
29. Germany FY 2016 
30. GibraltarFY beginning 1 July 2019 
31. Greece FY 2016 
32. Guernsey FY 2016 
33. Hong KongFY 2019
34. HungaryFY 2017
35. IcelandFY 2017
36. India FY 2016 
37. Indonesia FY beginning 1 May 2016 
38. Ireland FY 2016 
39. Isle of ManFY 2017
40. Italy FY 2016 
41. Japan FY 2016 
42. Jersey FY 2016 
43. KazakhstanFY 2017 
44. Korea FY 2016 
45. Latvia FY 2017 
46. LiechtensteinFY 2017
47. Lithuania FY 2016 
48. Luxembourg FY 2016 
49. MacauFY 2019 
50. MalaysiaFY 2017
51. MaldivesFY 2023
52. MaltaFY 2016 
53. MauritiusFY 2018
54. Mexico FY 2016 
55. Monaco FY 2018
56. Netherlands FY 2016 
57. New Zealand FY 2016 
58. Nigeria FY 2018 
59. Norway FY 2016 
60. OmanFY 2021 
61. Pakistan FY 2016
62. PanamaFY 2018
63. PeruFY 2017
64. Poland FY 2016 
65. Portugal FY beginning 1 August 2016 
66. Qatar FY 2017 
67. Romania FY 2016
68. RussiaFY 2017
69. San MarinoFY 2019
70. Saudi ArabiaFY 2018
71. SeychellesFY 2019
72. Slovak Republic FY 2016 
73. Slovenia FY 2016 
74. South Africa FY 2016 
75. Spain FY 2016 
76. Sweden FY 2016 
77. Switzerland FY 2018
78. TunisiaFY 2020
79. TürkiyeFY 2020
80. Turks & Caicos IslandsFY 2020
81. United Arab EmiratesFY 2019
82. United Kingdom FY 2016
83. United StatesFY 2021
84. Uruguay FY 2017

FY 20XX means FY beginning from 1 Jan 20XX. For example: FY 2016 means FY beginning 1 Jan 2016 while FY 2022 means FY beginning 1 Jan 2022.

Updated as at 10 Aug 2022.

FAQs

  1. What is the CbC MCAA?

    The CbC MCAA 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 CbC MCAA rests in Article 6 of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Convention) which provides for the AEOI between parties to the Convention, where 2 parties subsequently agree to do so. More information on the CbC MCAA, including the text of the MCAA, can be found on the OECD website.

  2. Why did Singapore sign the CbC MCAA?

    The signing of the CbC MCAA reaffirms Singapore’s commitment to the international standards on tax cooperation. The CbC MCAA has gained recognition internationally as a multilateral framework agreement for bilateral cooperation on AEOI of CbC Reports, with 57 signatories as at 1 Jun 2017.

    Signing the CbC MCAA will enable Singapore to efficiently establish a wide network of exchange relationships for the AEOI of CbC Reports.

  3. Does signing the CbC MCAA mean Singapore will exchange information with all MCAA signatories?

    No, signing the CbC MCAA 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 unauthorised use; and
    • There is full reciprocity with the AEOI partner in terms of the information exchanged.
  4. Which jurisdictions have an effective exchange relationship with Singapore under the CbC MCAA?

    The list of jurisdictions with an effective exchange relationship with Singapore is available on the OECD and IRAS website (see above).

CbCR Filing Requirements

Who needs to file the CbC Report

You will need to file a CbC Report with IRAS if you meet all of the following requirements:

  1. You are the ultimate parent entity of a Singapore MNE group;
  2. You are tax resident in Singapore;
  3. The consolidated group revenue for your MNE group in the preceding FY is at least S$1,125 million; and
  4. Your MNE group has subsidiaries or operations in at least 1 foreign jurisdiction.

When CbC Reports should be submitted

CbC Reports should be submitted to IRAS within 12 months from the end of the ultimate parent entity's FY.

For the purposes of CbCR, FY 2021 refers to FY beginning on or after 1 Jan 2021 but before 1 Jan 2022.

Examples

  • Ultimate parent entity's FY ends in Dec:
    The CbC Report relating to the financial period 1 Jan 2021 to 31 Dec 2021 (FY 2021) should be submitted to IRAS no later than 31 Dec 2022.
  • Ultimate parent entity's FY ends in Mar:
    The CbC Report relating to the financial period 1 Apr 2021 to 31 Mar 2022 (FY 2021) should be submitted to IRAS no later than 31 Mar 2023.

Information to be Included in the CbC Report Updated!

A CbC Report of an 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.

CbC Reports must be submitted based on the format specified in the ‘How to submit CbC Reports’ section below. You may refer to section 6 of the e-Tax Guide on Country-by-Country Reporting (PDF, 378KB) for details on the information to be submitted.

Notification of Filing Obligation Updated!

Before FY beginning on or after 1 Jan 2022

Each year, IRAS will issue notification letters to Reporting Entities on their obligation to file a CbC Report to IRAS for the preceding FY. For example, IRAS will send notification letters to Reporting Entities for the FY 2021 CbC Report by 31 Jul 2022.

If you are required to file a CbC Report for an FY (based on the CbCR filing requirements above) but have not received IRAS’ letter by 31 Jul of the following year, please email us immediately at [email protected].

Reporting Entities which are required to file a CbC Report must provide IRAS with the following information at least 3 months before the filing deadline via email to [email protected]:

  • Name and Tax Reference Number of the ultimate parent entity (i.e. Reporting Entity)
  • Financial reporting period of the ultimate parent entity (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 the above information)
From FY beginning on or after 1 Jan 2022 New!

With effect from from FY beginning on or after 1 Jan 2022, Reporting Entities must notify IRAS of their obligation to file a CbC Report via FormSG at https://go.gov.sg/cbcr, within 3 months from the end of their FY. The company director, principal officer or any person authorised by the company (including tax agents) can submit the notification via FormSG. IRAS will no longer issue notification letters to the Reporting Entities.

IRAS will verify the notifications filed by Reporting Entities and confirm their filing obligation within 2 months from the receipt of the notifications.

Entities Not Required to Notify IRAS

New! You are not required to notify IRAS if you are a Singapore Constituent Entity of a:

  • Singapore MNE group and you are not the Reporting Entity
  • Foreign MNE group

How to Submit the CbC Report

Reporting Entities will need to have processes in place to collate and prepare the data required in a CbC Report 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.

VersionStatusXML SchemaUser Guide
2.0Current

CbCR XML Schema v2.0 (ZIP, 17KB)

(OECD’s publication date: Jun 2019)

CbCR XML Schema User Guide for Tax Administrations (PDF, 3.43MB)

(For CbCR XML Schema version 2.0. OECD’s publication date: Jun 2019)

IRAS Supplementary Instructions for Preparing CbCR Data File (XLXS, 310KB)

(Updated for CbCR XML Schema version 2.0)

Reporting Entities must submit their XML CbC Reports via email to [email protected] with the following details Updated! :

  • Name and Tax Reference Number of the ultimate parent entity (i.e. Reporting Entity)
  • Financial reporting period of the ultimate parent entity (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 the Reporting Entity's behalf, if the third party is different from the one authorised by the Reporting Entity via Corppass

The XML CbC Report must be zipped (file extension must be in *.zip format) 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 provide us with the password via FormSG at https://go.gov.sg/cbcrpw.

^Note: Please use a strong password. It is recommended that the password should be:
- At least twelve characters; and
- Alphanumeric with at least 1 upper and lower case alphabet, number and symbol (e.g. PCrj57#u6Ew!).

Penalties for Non-Compliance

Failure to Notify, File a CbC Report, or to Retain Documents and Information

Updated! Companies may face the following penalties in cases of non-compliance:

Non-compliance Penalties
  • Failure to notify
  • Late filing or failure to file a CbC Report
  1. A fine of up to $5,000; imprisonment of up to 6 months for the person responsible for the offence where the fine is not paid
  2. A further daily fine of up to $100 during which the offence is continuing
Failure to retain documents and information used to prepare a CbC Report for 5 years after the end of the FY
  1. A fine of up to $1,000; imprisonment of up to 6 months for the person responsible for the offence where the fine is not paid
  2. A further daily fine of up to $50 during which the offence is continuing

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. An imprisonment term of up to 2 years for the person responsible for the offence.

For more details, refer to our e-Tax Guide on Country-by-Country Reporting (PDF, 378KB).

For enquiries, email us at [email protected].