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).