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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

All Reporting Singaporean Financial Institution (SGFIs) must submit their FATCA returns, including nil returns (if applicable) by 31 May of the year following the calendar year to which the return relates.

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.

As five months after the end of the reporting period is a reasonable deadline, no extensions will be granted.

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:

  1. the PIC is incorporated overseas and is a tax resident in Singapore;
  2. the PIC qualifies for S13F and S13N exemptions under the Income Tax Act 1947;
  3. the PIC is 100% owned by a SGFI; and
  4. the PIC does not maintain any reportable accounts as defined in the FATCA Regulations
Qualifying PICs may file its FATCA return annually using the simplified AEOI registration and reporting form.

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.

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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:

  1. Your Singpass; 
  2. The Reporting SGFI’s Singapore Tax Reference Number (e.g. UEN, ASGD or ITR); and
  3. FATCA returns (where applicable) (maximum file size 5MB)

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FATCA Submission Format

You will need to prepare your FATCA return either in XML format or in PDF format and submit it via myTax Portal. A nil return should be submitted if you do not have any reportable accounts in the reporting year.

XML Format

xml format

Fillable PDF Form

fillable pdf

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.
 

Nil Return

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

Reporting SGFIs should monitor the status of their submitted returns via the new digital service, "View CRS/FATCA Return Status" in myTax Portal.  Upon processing your return, a notification will be sent by IRAS within 5 working days confirming the acceptance or rejection of your return. Reporting SGFIs are expected to rectify all errors before the filing deadline. If your return is rejected, you can retrieve the errors via myTax Portal > Select Notice/Letters > AEOI.
FATCA return is accepted FATCA return is accepted with record-level error(s) or rejected
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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).

If you have received a notification from partners highlighting the errors in your FATCA return, “Record error(s) highlighted by Singapore AEOI partner(s)”, please review the error(s) and submit a “Correction FATCA return” to correct or void the erroneous record(s).

If you have received a notification from IRAS that your FATCA return has been “Rejected”, please rectify the error(s) and resubmit the FATCA return with a different MessageRefID.

Please resubmit the FATCA return to IRAS as a “Return with New Data”.

How to rectify the errors in FATCA return?

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    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
  • Please revalidate the file against the prevailing FATCA XML Schema (ZIP, 18KB) and resolve all validation errors before resubmitting the file to IRAS.
  •  Please ensure that you have performed a virus scan on the file and that there are no prohibited characters as outlined in Para 6.1 of the IRAS FATCA XML Schema User Guide (PDF,272KB).
   
2 9805 The GIIN provided in the ReportingFI.TIN data element in the return does not match the Reporting SGFI selected online.
  • Please ensure that the GIIN of the Reporting SGFI(s) provided in the FATCA return submitted matches the GIIN that was provided by the Reporting SGFI(s) to IRAS.
  • Reporting SGFIs can log in to myTax Portal, Select More > AEOI > View/Update FI AEOI Profile to check the GIIN that was provided to IRAS.
 
3 9806 The TDT Ref ID in the return does not belong to a TDT that is maintained by the Reporting SGFI.
  • Please ensure that the TDT Ref ID(s) in the FATCA return matches the TDT Ref ID(s) of the TDT that is maintained by the Reporting SGFI.
  • For submissions in XML format, the TDT Ref ID should be structured as follows: <Entity ID Type><Space><TDT Reference Number>, e.g. “TDT 1234567890”
 

 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).

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