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Singapore Issues Guidance On CbC Reporting

by Mary Swire,, Hong Kong

11 October 2016

The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory.

The guidance, released on October 10, sets out which entities are obliged to report and how to complete and submit a CbC report to IRAS.

For financial years beginning on or after January 1, 2017, CbC reporting is required from a Singaporean group if its consolidated group revenue exceeds SGD1.125bn (USD815m) and it has subsidiaries or operations in at least one other jurisdiction.

If a Singaporean group is obliged to file a CbC report, the ultimate parent entity must submit a CbC report within 12 months from the end of that financial year.

The CbC report must be filed electronically in the prescribed format and contain aggregate tax jurisdiction-wide information relating to the global allocation of the income, taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which the reporting MNE group operates.

It must also include a list of all the entities (including permanent establishments) for which financial information is reported, including the tax jurisdiction of incorporation, where different from the tax jurisdiction of residence, and the nature of the main business activities carried out.

The first CbC report required to be submitted to IRAS is due by December 31, 2018 (for a financial year ending on December 31, 2017). Penalties apply if a MNE fails to provide a required CbC report on time.

The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under Action 13 of the OECD's base erosion and profit shifting project.

Singapore will be introducing the Income Tax (Amendment) (No. 3) Bill 2016 in Parliament this year.

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