Country-by-Country Reporting (CbCR) for Singapore-headquartered multinational enterprises (MNEs)

Here is what you need to know.

Applicability

As per the current Guidelines issued by the Inland Revenue Authority of Singapore (IRAS), CbCR is applicable for Singapore headquartered MNE Groups from the Financial Year 2017 onwards.

Principally, CbCR is required for an MNE Group in relation to a financial year where:

1. The Group is Singapore headquartered;
2. The consolidated Group revenue in the preceding financial year is at least S$1,125 million; and
3. The MNE group has subsidiaries or operations in at least one foreign jurisdiction

Filing timeline

If a Singapore MNE Group is required to file a CbCR for a financial year, then the ultimate parent (or Reporting) entity will be required to submit the same within 12 months from the end of the financial year.

The submission must be done electronically in accordance with the specified format which is detailed and comprehensive.

Notification of filing obligation

With effect from Financial Year beginning on or after 1 January 2022, reporting entities must notify the Singapore tax authority of their obligation to file a CbCR vide a specified format within 3 months from the end of their Financial Year. The Company director, principal officer or any person authorised by the Company (including tax agents) can submit the notification as the tax authority will no longer issue notification letters to the Reporting Entities.

However, the above notification requirement would not apply if the Company were a Singapore Constituent Entity of a:

• Singapore MNE Group and is not the Reporting Entity
• Foreign MNE group

How Mazars can help

The preparation and delivery of the CbCR not only requires extensive work compiling the relevant accounting data, but a deep understanding of each jurisdiction’s CbCR requirements. Moreover, the CbCR notification applicability and requirement also requires detailed analysis and workings.

At Mazars, we have a team of dedicated Transfer Pricing experts who can help you keep your business tax compliant. We can analyse the applicability of CbCR filing requirement for the relevant financial year and/or provide on-going assistance in preparing the detailed filing/submission requirements as to ensure full compliance.

For further discussions, please contact Sahil Seth or Gene Kwee.