FATCA Filing Requirements
Under the FATCA Regulations, a Reporting SGFI is required to submit annual FATCA return(s) to IRAS setting out the required information in relation to every US Reportable Account that is maintained by the SGFI. Reporting SGFIs that did not maintain any
US 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 FATCA 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 FATCA Regulations. Company A is required to provide its FATCA Registration Information with IRAS before 31 Mar 2021 and needs to submit its FATCA return for its first Reporting Year 2020 to IRAS by 31 May 2021.
Penalties for Late Filing
Reporting SGFIs may face enforcement actions, including a penalty of up to $5,000, for late or non-filing of their FATCA returns.
Requesting for Filing Extensions
All Reporting SGFIs need to plan their resources to submit their FATCA 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 FATCA 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 FATCA matters|
|2||Key personnel overseas or resigned without proper handover|
|3||New staff does not know how to handle FATCA matters|
Simplified FATCA Registration and Filing Requirements for Qualifying Personal Investment Companies (PICs)
A PIC that is liable to fulfil FATCA reporting obligations may qualify for simplified FATCA registration and reporting requirements ("Qualifying PIC") if it does not have a tax reference number (e.g. UEN, ASGD or ITR Number) and meets all the following criteria:
- 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 FATCA Regulations
How to submit a FATCA return
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 FATCA Filing
Before filing the FATCA returns, please ensure that you have been authorised by the Reporting SGFI as an “Approver” for Automatic Exchange of Information (CRS and FATCA) Digital Services in Corppass. In authorising "Approver" in Corppass, Corppass Admin should leave the "Effective Reporting Year From" and "Effective Reporting Year To" fields as blank for the "Approver" to enable the "Approver" to submit returns for all Reporting Years.
For Non-UEN entities (e.g. Singaporean/foreign trusts or funds), the entity would have to first appoint a Corppass Admin via this link.
In addition to the steps above on the AEOI Digital Services authorisation, the Corppass Admin would also have to authorise the user as an "Approver" for the "For non-UEN entities only" Digital Services in order to access the AEOI services on myTax Portal. For more details, please refer to the guide. For assistance on Corppass setup, please refer to the step-by-step guides.
Step 2: Submit FATCA 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, ASGD or ITR); and
- FATCA returns (where applicable) (maximum file size 5MB)
- For more information on how to submit a FATCA return on myTax Portal, you may refer to the Submit CRS or FATCA Return User Guide (PDF, 460KB).
FATCA Submission 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 FATCA XML Schema V2.0 (ZIP, 18KB) (US IRS' Publication Date: 31 August 2016), US IRS FATCA XML Schema V2.0 User Guide (PDF, 1,182KB) (US IRS’ Publication 5124) and IRAS Supplementary XML User Guide for Preparing the FATCA Reporting Data File (PDF, 266KB).
The requirements are applicable to all submissions of new, nil, amended, corrected or void FATCA returns, including returns relating to Reporting Years 2018 and earlier.
|Alternatively, Reporting SGFIs can submit their FATCA returns using the fillable PDF form (PDF, 410KB), if they do not wish to acquire a reporting tool to generate the
FATCA 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.
FATCA Submission Status and Return Errors
|FATCA return is accepted||FATCA 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.
If you have received a notification from IRAS that your FATCA return has been “Accepted with record level error(s)”, please review the error(s) and submit an “Amended FATCA return” to correct or
void the erroneous record(s).
Please resubmit the FATCA return to IRAS as a “Return with New Data”.
How to rectify the errors in FATCA return?
- The Notice of AEOI Return Error will list the specific record that contains an error and the error code. Please refer to the
List of IRAS FATCA File and Record Level Errors (PDF, 239KB) for more information on the identified
error(s) and the necessary resolution(s).
List of Common FATCA Return Errors
|S/N||Error Code||Error Description||Resolution|
|1||NSV||The FATCA return failed validation against the FATCA XML Schema||
|2||9805||The GIIN provided in the ReportingFI.TIN data element in the return does not match the Reporting SGFI selected online.||
|3||9806||The TDT Ref ID in the return does not belong to a TDT that is maintained by the Reporting SGFI.||
Please refer to the List of IRAS FATCA File and Record Level Errors (PDF, 239KB) for the full list of FATCA return errors and the necessary resolution(s).