The e-Tax Guide has been updated with the following main changes:
Requirement for an ultimate parent entity of a Singapore-headquartered multinational enterprise group that is required to submit a Country-by-Country (CbC) Report to notify IRAS of its filing obligation from financial year beginning on or after 1 Jan 2022 (FY 2022), within 3 months from the end of that FY
Requirement to prepare CbC Reports in CbCR XML Schema format and submit the CbC Reports based on instructions on the IRAS CbCR webpage
Penalties for non-compliance
Updates to the frequently asked questions, including:
Question 2 – With effect from FY 2022, the definition of consolidated group revenue for the purpose of determining whether a Singapore MNE group is required to file a CbC Report should include extraordinary income and gains from investment activities.
The e-Tax Guide has been revised to provide clarity to the additional conditions to claim M&A tax benefits based on the 20% threshold and reflect the enhancement to the M&A scheme as announced in Budget 2022:
Expand the definition of “local employee” to (a) an individual who is hired under central hiring arrangements and deployed to the acquiring company; and (b) an individual who is seconded to the acquiring company
The implementation of Singapore’s notification requirement from financial year beginning on or after 1 Jan 2022, penalties for non-compliance and e-Tax Guide on CbCR have been updated.
The e-Tax Guide has been updated with the following changes:
Amended paragraph 1.1 to highlight that for the tax treatment of an insurer for its financial years beginning on or after 1 Jan 2023 or such earlier period as may be approved by CIT, to refer to the e-Tax Guide “Taxation of Insurers Arising
from Adoption of FRS 117 – Insurance Contracts.”
Amended paragraph 8 to update the tax treatment for insurers following the de-recognition of reinsurance arrangements between a Head Office and its branch in Singapore from 1 Jan 2022.
Inserted paragraphs 21 to 24 in Annex A on the application of the offsetting rules for par fund surplus or loss apportioned to policyholders.
Made editorial changes as RBC 2 took effect in 2020 after the issuance of the e-Tax guide (First Edition).
The e-Tax Guide has been updated with the following changes:
Amended Abbreviations to add the terms “FRS”, “FRS 117” and SFRS(I) 17 and to update the short title of the ITA based on the 2020 Revised Edition of the ITA.
Inserted paragraph 2.4 to refer the following taxpayers to the IRAS e-Tax Guide as mentioned in that paragraph for guidance on the tax treatment for financial instruments of licensed insurers and examples where the CIT may consider allowing
an early adoption of the use of MAS Statutory Returns as the basis for preparing their tax computations:
licensed insurers who have applied FRS 117 in preparing financial statements; and
licensed insurers who have sought and obtained the CIT’s approval to early adopt the use of MAS Statutory Returns as the basis for preparing their tax computations.
Amended paragraph 4.3 and the table at paragraph 6.5 to clarify the tax treatment for interest income from loans that is chargeable to tax under section 10(1)(d).
Amended paragraphs 6.20, 6.21 and 6.23, footnotes 16 and 19, and Annex B to update the reference made to section 14I to section 14G as the provision has been renumbered in the 2020 Revised Edition of the ITA.
Amended footnote 18 to refer to section 14G(6B) of the ITA for the period in which the tax deduction under section 14G is allowed.
Amended paragraph 6.34 for clarity.
Inserted paragraph 7.4 to refer an insurer who has applied FRS 117 for accounting purpose to the IRAS e-Tax Guide as mentioned in paragraph 2.4 for guidance on determining the values of assets to be used in the TAM for computing interest adjustment.
Amended paragraph 10.2(a) and footnote 48 to reflect the extended date for the temporary exemption from applying FRS 109 as announced on 27 Nov 2020.
Inserted paragraph 10.6 to inform about the disapplication of pre-FRS 39 tax treatment, FRS 39 tax treatment and FRS 109 tax treatment to a licensed insurer, starting from the YA of the basis period in which FRS 117 is first applied for accounting
purpose or such earlier YA as may be approved by CIT, and to refer an affected licensed insurer to the IRAS e-Tax Guide as mentioned in paragraph 2.4 for guidance on the tax treatment for financial instruments of the affected licensed insurers.
Amended footnotes 4, 11 and 47 to update the cross-references made to the relevant accounting standards due to the incorporation of the amendments contained in Appendix C of FRS 109 (issued in 2014) into the relevant accounting standards
in the 2018 volume.
Amended footnotes 33 and 34 to indicate the volume of FRS 39 which contains the information.