Country By Country Reporting

Who needs to file the CbCR?

Singapore-headquartered MNEs meeting the following requirements are required to file a CbCR with IRAS:

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

When should CbCR be submitted?

CbCR should be submitted to IRAS within 12 months from the end of the ultimate parent entity's FY[1].

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

Am I to notify IRAS on CbCR obligations?

With effect from FY beginning on or after 1 Jan 2022, Reporting Entities must notify IRAS of their obligation to file a CbCR within 3 months from the end of FY. IRAS will verify the notifications filed by Reporting Entities and confirm their filing obligation within 2 months from the receipt of the notifications.

What type of information does the CbCR Notification form require?

The CbCR notification form requires the following information to be submitted to IRAS:

Particulars of Ultimate Parent Entity, such as: name, tax reference number and financial period;
Particulars of contact person, such as: Name, designation and contact details of company director or principal officer; and
Declaration: Declaring that the reporting entity has met requirement to file the CbCR, and, Name, designation and contact details of company director, principal officer or any person authorised by the company (including tax agents).

What type of information does the CbCR form require?

The CbCR form requires MNEs to report details, by jurisdiction, regarding their global and local operations and activities. Specifically, the form is divided into three (3) tables that require the following information:

Table	Reference to Form	Type of Information
1	Business information	Business information relating to the MNE such as: Entity name and Address; Tax Identification Number (“TIN”); and Language and Contact information.
2	Table 1	Information relating to the Group such as: Entity names and Addresses; TIN; Segregated revenue (between related and unrelated parties); Profit before income and taxes; Income tax paid (on cash basis and accrued); Capital and Accumulated earning; Number of employees; and Tangible assets.
3	Table 2	Information or explanatory notes to facilitate the understanding of the compulsory information provided in Table 1 above. These could include details of exchange rates used (if applicable) or information based management accounts instead of audited financials.

How to submit the CbCR?

CbCR filling to IRAS is required to be submitted in accordance with the prevailing CbCR XML Schema. Data submitted to IRAS in any other format will not be accepted.

Reporting entities will submit the completed CbCR XML Schema (Zipped and Password protected) and email IRAS with the following details:

Name and Tax Reference Number of the ultimate parent entity (i.e. Reporting Entity);
Financial reporting period of the ultimate parent entity; and
If applicable, a letter of authority for a third party (e.g. a tax agent) to file on the Reporting Entity's behalf.

Are there any penalties for non-compliance?

Penalties for non-compliance are highlighted in the table below:

No.	Non Compliance	Penalty
1	Failure to notify	A fine of up to SGD 5,000; imprisonment of up to 6 months for the person responsible for the offence where the fine is not paid; and A further daily fine of up to SGD 100 during which the offence is continuing.
2	Late filling or failure to file a CbCR	As above
3	Failure to retain documents and information	A fine of up to SGD 1,000; imprisonment of up to 6 months for the person responsible for the offence where the fine is not paid; and A further daily fine of up to SGD 50 during which the offence is continuing.
4	False / misleading information	A fine of up to SGD 1,000; imprisonment of up to 6 months for the person responsible for the offence where the fine is not paid; and A further daily fine of up to SGD 50 during which the offence is continuing.

Are CBC Reports Automatically exchanged?

On 21 Jun 2017, Singapore signed the Multilateral Competent Authority Agreement on the exchange of CbCRs (“CbC MCAA”).

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 CbCRs. Under the CbC MCAA, signatories to the MCAA will automatically exchange CbCRs with one another on a bilateral basis if both parties are mutually agreeable.

CbCR 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.

Analyse CbCR Status

We assess your MNE's structure and operations to determine if CbCR obligations apply, especially in complex situations where multiple entities and jurisdictions are involved.

Notification Submission

Our experts manage the streamlined notification submission process, ensuring all necessary information is included and submitted to the Inland Revenue Authority of Singapore (IRAS) within the required timeframe.

Prepare CbCR Form

We have the knowledge and experience to prepare the CbCR form accurately, including all required details and information related to your MNE's global and local operations.

XML Templates & Conversion

With access to up-to-date CbCR form templates, we assist in filling out the form and converting it into an XML Schema format, ready for submission to IRAS.

Lodge CbCR Form

We handle the submission of the completed CbCR form to IRAS, ensuring all requirements are met and the form is submitted correctly.

Reqests for Extensions

Our team works closely with IRAS to request extensions for deadlines when necessary, providing you with additional time to complete and submit the CbCR form.