Introduction
Singapore implement Country-by-Country Reporting (CbCR) under the Base Erosion and Profit Shifting (BEPS) Project for Singapore Multinational Enterprises (MNEs) groups from financial year (FY) beginning on or after 1 January 2017 that meet certain conditions to prepare and file Country-by-Country (CbC) Reports to Inland Revenue Authority of Singapore (IRAS).
Some jurisdictions would be implementing CbCR for FY beginning on or after 1 January 2016. In which case, affected Singapore MNEs may file a CbC Report for FY 2016 to IRAS on a voluntary basis.
CbCR will be supplementary information to the group and local entity level documentation required to be maintained as per the IRAS’s Transfer Pricing Guidelines.
CbC Reports
On 26 October 2018, the Income Tax (International Tax Compliance Agreements) (Multilateral Competent Authority Agreement on the Exchange of Country-By-Country Reports) Order 2018 was published in the Singapore Government Gazette.
The First and Second Schedules of the Order 2018 list the 42 countries in which the IRAS will exchange CbC reports with.
The Third Schedule adds 11 more countries to the Multilateral Competent Authority Agreement on the Exchange of Country-By-Country Reports of which Singapore has an agreement with that are effective from 30 March 2018:
- Cayman Islands
- Hungary
- Iceland
- Isle of Man
- Liechtenstein
- Mauritius
- Pakistan
- Romania
- Russian Federation
- Switzerland
- Uruguay
2 more countries were added in Fourth Schedule and effective from 26 July 2018:
- Costa Rica
- Malaysia
Source: Government Gazette, Electronic Edition, 28 October 2018