Singapore-headquartered multinational enterprise (MNE) groups meeting certain requirements are required to prepare and file CbC Reports to IRAS for financial years (FYs) beginning on or after 1 Jan 2017 within 12 months from the end of their FY.
For FY beginning on or after 1 Jan 2022, these Singapore MNE groups are also required to notify IRAS of their obligation to file a CbC Report, within 3 months from the end of that relevant FY.
On this page:
What is CbCR?
CbCR is a form of reporting by MNEs initiated by the Organisation for Economic Co-operation and Development (OECD) in the Base Erosion and Profit Shifting (BEPS) Action 13 Report. In keeping with Singapore’s commitment to implement certain measures under the BEPS Project, Singapore-headquartered MNEs meeting certain requirements must prepare and file CbC Reports to IRAS for FYs beginning on or after 1 Jan 2017.
Qualifying Competent Authority Agreement
On 21 Jun 2017, Singapore signed the Multilateral Competent Authority Agreement on the exchange of CbC Reports (CbC MCAA). The signing of the CbC MCAA will enable Singapore to efficiently establish a wide network of exchange relationships for the automatic exchange of CbC Reports. View the press release.
The CbC MCAA is a multilateral framework agreement based on the Convention on Mutual Administrative Assistance in Tax Matters. It provides a standardised and efficient mechanism to facilitate the automatic exchange of CbC Reports. Under the CbC MCAA, signatories to the MCAA will automatically exchange CbC Reports with one another on a bilateral basis if both parties are mutually agreeable.
CbC Reports submitted to IRAS will be provided to tax authorities of jurisdictions with which Singapore has established bilateral Automatic Exchange of Information (AEOI) relationships under the MCAA. At the present time, not all signatories to the MCAA have provided full or complete notifications of their intended exchange relationships. Some jurisdictions may also increase their exchange relationships over time. The list of exchange relationships below is therefore not the final list of exchange relationships that Singapore will enter into. For more information, please visit the OECD webpage.
List of Jurisdictions
| Jurisdiction | Exchange relationship effective from |
|---|---|
| 1. Albania [NEW!] | FY 2024 |
| 2. Andorra | FY 2018 |
| 3. Anguilla | FY 2019 |
| 4. Argentina | FY 2017 |
| 5. Aruba | FY beginning 1 May 2021 |
| 6. Australia | FY 2016 |
| 7. Austria | FY beginning 1 June 2016 |
| 8. Azerbaijan | FY 2020 |
| 9. Bahamas | FY 2019 |
| 10. Bahrain | FY 2021 |
| 11. Barbados | FY beginning 1 August 2021 |
| 12. Belgium | FY 2016 |
| 13. Belize | FY 2019 |
| 14. Bermuda | FY 2017 |
| 15. Brazil | FY 2016 |
| 16. British Virgin Islands | FY 2018 |
| 17. Bulgaria | FY 2016 |
| 18. Canada | FY 2017 |
| 19. Cayman Islands | FY 2016 |
| 20. Chile | FY 2017 |
| 21. China | FY 2017 |
| 22. Colombia | FY 2016 |
| 23. Costa Rica | FY 2017 |
| 24. Croatia | FY 2017 |
| 25. Curacao | FY 2018 |
| 26. Cyprus | FY 2017 |
| 27. Czech Republic | FY beginning 1 October 2016 |
| 28. Denmark | FY 2016 |
| 29. Estonia | FY beginning 1 August 2016 |
| 30. Faroe Islands | FY beginning 1 August 2021 |
| 31. Finland | FY 2016 |
| 32. France | FY 2016 |
| 33. Georgia [NEW!] | FY 2024 |
| 34. Germany | FY 2016 |
| 35. Gibraltar | FY beginning 1 July 2019 |
| 36. Greece | FY 2016 |
| 37. Guernsey | FY 2016 |
| 38. Hong Kong | FY 2019 |
| 39. Hungary | FY 2017 |
| 40. Iceland | FY 2017 |
| 41. India | FY 2016 |
| 42. Indonesia | FY beginning 1 May 2016 |
| 43. Ireland | FY 2016 |
| 44. Isle of Man | FY 2017 |
| 45. Israel | FY 2021 |
| 46. Italy | FY 2016 |
| 47. Japan | FY 2016 |
| 48. Jersey | FY 2016 |
| 49. Kazakhstan | FY 2017 |
| 50. Kenya | FY 2022 |
| 51. Korea | FY 2016 |
| 52. Latvia | FY 2017 |
| 53. Liechtenstein | FY 2017 |
| 54. Lithuania | FY 2016 |
| 55. Luxembourg | FY 2016 |
| 56. Macau | FY 2019 |
| 57. Malaysia | FY 2017 |
| 58. Maldives | FY 2023 |
| 59. Malta | FY 2016 |
| 60. Mauritius | FY 2018 |
| 61. Mexico | FY 2016 |
| 62. Monaco | FY 2018 |
| 63. Montserrat | FY 2024 |
| 64. Netherlands | FY 2016 |
| 65. New Zealand | FY 2016 |
| 66. Nigeria | FY 2018 |
| 67. Norway | FY 2016 |
| 68. Oman | FY 2021 |
| 69. Pakistan | FY 2016 |
| 70. Panama | FY 2018 |
| 71. Papua New Guinea | FY 2024 |
| 72. Peru | FY 2017 |
| 73. Poland | FY 2016 |
| 74. Portugal | FY beginning 1 August 2016 |
| 75. Qatar | FY 2017 |
| 76. Romania | FY 2016 |
| 77. Russia | FY 2017 |
| 78. San Marino | FY 2019 |
| 79. Saudi Arabia | FY 2018 |
| 80. Seychelles | FY 2019 |
| 81. Slovak Republic | FY 2016 |
| 82. Slovenia | FY 2016 |
| 83. South Africa | FY 2016 |
| 84. Spain | FY 2016 |
| 85. Sweden | FY 2016 |
| 86. Switzerland | FY 2018 |
| 87. Thailand | FY 2023 |
| 88. Tunisia | FY 2020 |
| 89. Türkiye | FY 2020 |
| 90. Turks & Caicos Islands | FY 2020 |
| 91. Ukraine | FY 2023 |
| 92. United Arab Emirates | FY 2019 |
| 93. United Kingdom | FY 2016 |
| 94. United States | FY 2021 |
| 95. Uruguay | FY 2017 |
FY 20XX means FY beginning from 1 Jan 20XX. For example: FY 2016 means FY beginning 1 Jan 2016 while FY 2022 means FY beginning 1 Jan 2022.
Updated as at 11 Oct 2024.
FAQs
What is the CbC MCAA?
The CbC MCAA is a multilateral framework agreement that provides a standardised and efficient mechanism to facilitate the automatic exchange of CbC Reports. The legal basis for the CbC MCAA rests in Article 6 of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Convention) which provides for the AEOI between parties to the Convention, where 2 parties subsequently agree to do so. More information on the CbC MCAA, including the text of the MCAA, can be found on the OECD website.
Why did Singapore sign the CbC MCAA?
The signing of the CbC MCAA reaffirms Singapore’s commitment to the international standards on tax cooperation. The CbC MCAA has gained recognition internationally as a multilateral framework agreement for bilateral cooperation on AEOI of CbC Reports, with 57 signatories as at 1 Jun 2017.
Signing the CbC MCAA will enable Singapore to efficiently establish a wide network of exchange relationships for the AEOI of CbC Reports.
Does signing the CbC MCAA mean Singapore will exchange information with all MCAA signatories?
No, signing the CbC MCAA does not mean Singapore will automatically exchange CbC Reports with all the signatories.
Under the MCAA, each signatory has ultimate control over exactly which exchange relationships it enters into and that each signatory’s standards on confidentiality, data protection and appropriate use of information will always apply. Singapore will establish bilateral AEOI relationships with fellow signatories that can meet the following principles:
- The AEOI partner has the safeguards needed to ensure the confidentiality of information exchanged and prevent its unauthorised use; and
- There is full reciprocity with the AEOI partner in terms of the information exchanged.
Which jurisdictions have an effective exchange relationship with Singapore under the CbC MCAA?
The list of jurisdictions with an effective exchange relationship with Singapore is available on the OECD and IRAS website (see above).
CbCR Filing Requirements
Who needs to file the CbC Report
You will need to file a CbC Report with IRAS if you meet all of the following requirements:
- You are the ultimate parent entity of a Singapore MNE group;
- You are tax resident in Singapore;
- The consolidated group revenue for your MNE group in the preceding FY is at least S$1,125 million; and
- Your MNE group has subsidiaries or operations in at least 1 foreign jurisdiction.
When CbC Reports should be submitted
CbC Reports should be submitted to IRAS within 12 months from the end of the ultimate parent entity's FY.
For the purposes of CbCR, FY 2021 refers to FY beginning on or after 1 Jan 2021 but before 1 Jan 2022.
Examples
- Ultimate parent entity's FY ends in Dec:
The CbC Report relating to the financial period 1 Jan 2021 to 31 Dec 2021 (FY 2021) should be submitted to IRAS no later than 31 Dec 2022. - Ultimate parent entity's FY ends in Mar:
The CbC Report relating to the financial period 1 Apr 2021 to 31 Mar 2022 (FY 2021) should be submitted to IRAS no later than 31 Mar 2023.
Information to be Included in the CbC Report
A CbC Report of an MNE group will include information on the group’s global allocation of the income and taxes paid in different jurisdictions and other financial data. CbC Reports submitted to IRAS will be provided to tax authorities of jurisdictions with which Singapore has qualifying competent authority agreements for the automatic exchange of CbCR information. CbC Reports may be used by Singapore and other tax authorities in evaluating transfer pricing risks and other BEPS-related risks.
CbC Reports must be submitted based on the format specified in the ‘How to submit CbC Reports’ section below. You may refer to section 6 of the e-Tax Guide on Country-by-Country Reporting (PDF, 378KB) for details on the information to be submitted.
Notification of Filing Obligation
Before FY beginning on or after 1 Jan 2022
Each year, IRAS will issue notification letters to Reporting Entities on their obligation to file a CbC Report to IRAS for the preceding FY. For example, IRAS will send notification letters to Reporting Entities for the FY 2021 CbC Report by 31 Jul 2022.
If you are required to file a CbC Report for an FY (based on the CbCR filing requirements above) but have not received IRAS’ letter by 31 Jul of the following year, please email us immediately at [email protected].
Reporting Entities which are required to file a CbC Report must provide IRAS with the following information at least 3 months before the filing deadline via email to [email protected]:
- Name and Tax Reference Number of the ultimate parent entity (i.e. Reporting Entity)
- Financial reporting period of the ultimate parent entity (DD/MM/YYYY to DD/MM/YYYY)
- Contact person’s name and contact number
- Email of contact person (if different from that used to provide the above information)
From FY beginning on or after 1 Jan 2022
With effect from from FY beginning on or after 1 Jan 2022, Reporting Entities must notify IRAS of their obligation to file a CbC Report via FormSG at https://go.gov.sg/cbcr, within 3 months from the end of their FY. The company director, principal officer or any person authorised by the company (including tax agents) can submit the notification via FormSG. IRAS will no longer issue notification letters to the Reporting Entities.
IRAS will verify the notifications filed by Reporting Entities and confirm their filing obligation within 2 months from the receipt of the notifications.
Entities Not Required to Notify IRAS
You are not required to notify IRAS if you are a Singapore Constituent Entity of a:
- Singapore MNE group and you are not the Reporting Entity
- Foreign MNE group
How to Submit the CbC Report
Reporting Entities will need to have processes in place to collate and prepare the data required in a CbC Report in accordance with the prevailing CbCR XML Schema set out in the table below. Data submitted to IRAS in any other format will not be accepted.
| Version | Status | XML Schema | User Guide |
|---|---|---|---|
| 2.0 | Current | CbCR XML Schema v2.0 (ZIP, 17KB) (OECD’s publication date: Jun 2019) | CbCR XML Schema User Guide for Tax Administrations (PDF, 3.43MB) (For CbCR XML Schema version 2.0. OECD’s publication date: Jun 2019) IRAS Supplementary Instructions for Preparing CbCR Data File (XLXS, 310KB) (Updated for CbCR XML Schema version 2.0) |
Reporting Entities must submit their XML CbC Reports via email to [email protected] with the following details :
- Name and Tax Reference Number of the ultimate parent entity (i.e. Reporting Entity)
- Financial reporting period of the ultimate parent entity (DD/MM/YYYY to DD/MM/YYYY)
- If applicable, a letter of authority for a third party (e.g. a tax agent) to file on the Reporting Entity's behalf, if the third party is different from the one authorised by the Reporting Entity via Corppass
The XML CbC Report must be zipped (file extension must be in *.zip format) and password-protected^, with the Reporting Entity's name as the name of the file (e.g. ABC Ltd.zip). After you have emailed your CbC Report, please provide us with the password via FormSG at https://go.gov.sg/cbcrpw.
^Note: Please use a strong password. It is recommended that the password should be:
- At least twelve characters; and
- Alphanumeric with at least 1 upper and lower case alphabet, number and symbol (e.g. PCrj57#u6Ew!).
Penalties for Non-Compliance
Failure to Notify, File a CbC Report, or to Retain Documents and Information
Companies may face the following penalties in cases of non-compliance:
| Non-compliance | Penalties |
|---|---|
|
|
| Failure to retain documents and information used to prepare a CbC Report for 5 years after the end of the FY |
|
False/ Misleading CbC Information
A company which provides false or misleading CbC information may face the following consequences:
- A fine of up to $10,000; and/or
- An imprisonment term of up to 2 years for the person responsible for the offence.
For more details, refer to our e-Tax Guide on Country-by-Country Reporting (PDF, 378KB).
For enquiries, email us at [email protected].