The Inland Revenue Authority of Singapore (IRAS) issued an e-Tax Guide on Country-by-Country Reporting. Singapore-headquartered MNEs meeting certain conditions are required to prepare and file CbC Reports to the IRAS for financial years beginning on or after January 1, 2017.
A CbC Report of the MNE group will include information on the group’s global allocation of the income and taxes paid in different countries and other financial data. These will be shared with tax authorities of countries with which Singapore has signed bilateral agreements for 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, the IRAS has informed.
The ultimate parent entity of the Singapore MNE group will be required to file a CbC Report for all entities in the group. The MNE group is required to submit the CbC Report if it meets all of the following conditions:
The ultimate parent entity of the MNE group is a tax resident in Singapore;
The consolidated group revenue for the MNE group in the financial year is at least S$1,125 million;
The CbC Report should be submitted to the IRAS within 12 months from the end of the ultimate parent entity's financial year.
The new e-Tax guide provides taxpayers with guidance on:
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