Country-by-Country Reporting (CbCR) is a form of reporting by multinational enterprises (MNEs) initiated by the Organisation for Economic Co-operation and Development (OECD) in the Base Erosion and Profit Shifting (BEPS) Action 13 Report. Some jurisdictions would be implementing CbCR for Financial Year (FY) beginning on or after 1 January 2016. To address the transition issue arising from this, affected Singapore-headquartered MNEs may file a CbC Report for FY beginning on or after 1 Jan 2016 to IRAS on a voluntary basis, i.e. Voluntary Filing.
Singapore is implementing CbCR for Singapore MNE groups from FY 2017 onwards. CbCR is required for an MNC group in relation to a financial year (the first such year being FY 2017), where:
(a) The MNE group is a Singapore MNE group;
(b) The consolidated group revenue in the preceding financial year is at least S$1,125 million; and
(c) The MNE group has subsidiaries or operations in at least one foreign jurisdiction.
FY 2017 refers to financial years beginning on or after 1 January 2017 but before 1 January 2018.
A CbC Report of the 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.
On 11 July 2018, the Inland Revenue Authority of Singapore (IRAS) has updated their content on the Second Edition of e-Tax Guide – Country-by-Country-Reporting (CbCR) on filing for financial years beginning on or after 1 January 2017:
- IRAS has sent letters to Reporting Entities notifying them of their obligation to file a CbC Report for FY 2017.
- If the reporting entities do not received IRAS’ letter by 31 July 2018, they must contact IRAS immediately by email (to ct_transfer_pricing@iras.gov.sg).
- Reporting Entities must provide IRAS with the following information at least 3 months before the filing deadline by email:
- Name and UEN of the UPE (i.e. Reporting Entity);
- Financial reporting period of the UPE (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 your reply).
- Reporting entities must submit their FY 2017 XML CbC reports via email with the following details:
- Name of the UPE (i.e. Reporting Entity);
- Financial reporting period (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 their behalf, if the third party is different from the one they have authorised via EASY.
- The XML CbC report must be zipped and password-protected, with the Reporting Entity’s name as the name of the file (e.g. ABC Ltd.zip). After emailed the CbC report, they must call IRAS at 6351 2609 (Mondays to Fridays, 8 am to 5 pm) to provide IRAS the password to open the report.
Source: IRAS, 31 July 2018
