Ad.

1 Aim
1.1 This e-Tax Guide provides taxpayers with guidance on:
(a) The purpose of CbCR;
(b) The obligation to submit a notice that a Reporting Entity is required to
provide a CbC Report (“notification of filing obligation”);
(c) The obligation to provide a CbC Report;
(d) How to complete a CbC Report; and
(e) How to submit a CbC Report to the Comptroller.
1.2 This e-Tax Guide is relevant to any Singapore MNE group with international
operations and annual group revenue of at least S$1,125 million.
2 Glossary
2.1 The following terms are used in this e-Tax Guide:
AEOI: Automatic exchange of information
BEPS: Base Erosion and Profit Shifting
CbCR: Country-by-Country Reporting
CbC Report: Country-by-Country Report
FY 20XX: Financial year beginning on or after 1 January 20XX (but before 1 January of the following year)
IRAS CbCR webpage: This webpage provides information on CbCR and
its implementation in Singapore.
MNE: Multinational enterprise

OECD: Organisation for Economic Cooperation and
Development
Reporting Entity /Reporting MNE: The entity of an MNE group that is required to file a CbC Report
Singapore MNE group: MNE group whose ultimate parent entity is tax resident in Singapore for the financial year in which the CbC Report is prepared (the first such year being FY 2017)

3 At a glance
3.1 In the Final Report on BEPS Action 13 “Transfer Pricing Documentation and
Country-by-Country Reporting” published by the OECD in October 2015, a
new form of reporting namely CbCR would form part of the transfer pricing
documentation to be maintained by MNEs.
3.2 Singapore has implemented CbCR for Singapore MNE groups from FY 2017.
3.3 Broadly, CbCR is required for an MNE group in relation to a financial year
(the first such year being FY 2017), where:
(a) The MNE group is a Singapore MNE group;
(b) The consolidated group revenue in the preceding financial year is at
least S$1,125 million; and
(c) The MNE group has subsidiaries or operations in at least one foreign
tax jurisdiction.
3.4 If a Singapore MNE group is required to file a CbC Report for a financial year,
its ultimate parent entity, which is its Reporting Entity for the purpose of CbCR,
will be required to submit a CbC Report to the Comptroller within 12 months
from the end of that financial year. From FY 2022 onwards, the Reporting
Entity is also required to notify the Comptroller of its obligation to file a CbC
Report, within three months from the end of that financial year.
3.5 Notification of filing obligation and submission of CbC Reports must be done electronically in accordance with the format and mode specified in this e-Tax Guide.
3.6 Based on the identification of relevant tax jurisdictions in a CbC Report
submitted by a Reporting Entity, the Comptroller will provide the CbC Report
to the tax authorities of those jurisdictions if there is an agreement with the
relevant tax authority for the automatic exchange of CbCR information.
3.7 Any information that is obtained by a tax authority from CbC Reports through AEOI is strictly confidential.
4 Transfer pricing documentation
4.1 IRAS e-Tax Guide on Transfer Pricing Guidelines requires taxpayers to
organise their transfer pricing documentation at Group level and Entity level.
4.2 CbC Reports are supplementary to such transfer pricing documentation.

4.3 A CbC Report requires aggregate tax jurisdiction-wide information relating to the global allocation of the income, the taxes paid, and certain indicators of
the location of economic activity among tax jurisdictions in which the reporting
MNE group operates. The CbC Report also requires a listing of all the entities
(including permanent establishments) for which financial information is
reported, including the tax jurisdiction of incorporation, where different from
the tax jurisdiction of residence, as well as the nature of the main business
activities carried out.
4.4 A CbC Report will be helpful for high-level transfer pricing risk assessment
purposes. It may also be used by tax authorities in evaluating other BEPSrelated risks and where appropriate for economic and statistical analysis. The
information in the CbC Report should not be used as a substitute for a
detailed transfer pricing analysis of individual transactions and prices
based on a fully functional analysis and a full comparability analysis.
The information in the CbC Report on its own does not constitute
conclusive evidence that transfer prices are or are not appropriate. It
should not be used by tax administrations to propose transfer pricing
adjustments.
5 Notification of filing obligation
5.1 Singapore is implementing a notification requirement from FY 2022. The
Reporting Entity of a Singapore MNE group is required to inform the
Comptroller of its obligation to file a CbC Report for each financial year that
the group is required to file. A notification process allows a Reporting Entity
and the Comptroller to confirm in advance the Reporting Entity’s filing
obligation, thus providing early certainty to both parties.
5.2 A Reporting Entity must submit the notification to the Comptroller within three months from the end of the relevant financial year together with the following information:

Name and Tax Reference No. of the ultimate parent entity (i.e.
Reporting Entity);

Financial reporting period;

A declaration that the Reporting Entity satisfies the requirements to
submit a CbC Report for that financial reporting period;

Personal particulars (i.e. full name, designation, contact number and
email) of an individual authorised by the Reporting Entity as the point of
contact; and

Personal particulars of the individual authorised by the Reporting Entity
to file the notification.

5.3 Reporting Entities must submit the above information to the Comptroller in
the form and manner as stated on the IRAS CbCR webpage.

5.4 The Comptroller will review the information received and provide confirmation of a Reporting Entity’s filing obligation within two months from the receipt of
the notification.
6 Format of CbC Reports
6.1 CbC Reports must be submitted in accordance with the template in the Annex to this e-Tax Guide.
6.2 A CbC Report comprises three tables:
(a) Table 1 provides an overview of income, taxes, employees and assets
of the MNE group allocated to the different tax jurisdictions that the MNE
group operates in, i.e. each line reports the aggregated numbers
relating to a particular tax jurisdiction. For example, if an MNE group
has income arising from three tax jurisdictions, this table will show three
lines – one for each tax jurisdiction.
(b) Table 2 provides an overview of the entities (including permanent
establishments) of the MNE group, again organised according to the tax
jurisdictions that the entities are tax resident in. The main business
activities of each entity are also indicated. Dormant entities must also
be included in this table.
(c) Table 3 allows the MNE group to provide any additional information that
it feels would be relevant and useful to interpret or understand the data
provided in the CbC Report.
6.3 The following definitions should be followed in completing the CbC Report
template:
MNE
An MNE is a multinational enterprise.
Reporting MNE
A Reporting MNE is the ultimate parent entity of an MNE group.
Constituent Entity
A Constituent Entity of the MNE group is (i) any separate business unit of an
MNE group that is included in the Consolidated Financial Statements of the
MNE group for financial reporting purposes, or would be so included if equity
interests in such business unit of the MNE group were traded on a public
securities exchange; (ii) any such business unit that is excluded from the
MNE group’s Consolidated Financial Statements solely on size or materiality
grounds; and (iii) any permanent establishment of any separate business unit
of the MNE group included in (i) or (ii) above provided the business unit prepares a separate financial statement for such permanent establishment
for financial reporting, regulatory, tax reporting, or internal management
control purposes.
Consolidated Financial Statements
The Consolidated Financial Statements are the financial statements of an
MNE group in which the assets, liabilities, income, expenses and cash flows
of the ultimate parent entity and the Constituent Entities are presented as
those of a single economic entity.
6.4 The following general instructions should be followed in completing the CbC
Report template:
Treatment of Branches and Permanent Establishments
The permanent establishment data should be reported by reference to the
tax jurisdiction in which it is situated and not by reference to the tax
jurisdiction of residence of the business unit of which the permanent
establishment is a part. Residence tax jurisdiction reporting for the business
unit of which the permanent establishment is a part should exclude financial
data related to the permanent establishment.
Treatment of partnerships
Applicable accounting rules will determine whether a partnership is a
Constituent Entity. If a partnership is a Constituent Entity, it is treated as any
other Constituent Entity (e.g. a company).
Period covered by the annual template
The template should cover the fiscal year of the Reporting MNE. For
Constituent Entities, at the discretion of the Reporting MNE, the template
should reflect on a consistent basis either (i) information for the fiscal year of
the relevant Constituent Entities ending on the same date as the fiscal year
of the Reporting MNE, or ending within the 12-month period preceding such
date, or (ii) information for all the relevant Constituent Entities reported for
the fiscal year of the Reporting MNE.
Source of data
The Reporting MNE should consistently use the same sources of data from
year to year in completing the template. The Reporting MNE may choose to
use data from its consolidation reporting packages, from separate entity
statutory financial statements, regulatory financial statements, or internal
management accounts. It is not necessary to reconcile the revenue, profit
and tax reporting in the template to the consolidated financial statements. If
statutory financial statements are used as the basis for reporting, all amounts
should be translated to the stated functional currency of the Reporting MNE
at the average exchange rate for the year stated in the Additional Information
section of the template. Adjustments need not be made, however, for differences in accounting principles applied from tax jurisdiction to tax
jurisdiction.
The Reporting MNE should provide a brief description of the sources of data
used in preparing the template in the Additional Information section of the
template. If a change is made in the source of data used from year to year,
the Reporting MNE should explain the reasons for the change and its
consequences in the Additional Information section of the template.
6.5 The following specific instructions should be followed in completing Table 1
of the CbC Report template:
Tax Jurisdiction
In the first column of the template, the Reporting MNE should list all of the
tax jurisdictions in which Constituent Entities of the MNE group are resident
for tax purposes. A tax jurisdiction is defined as a State as well as a nonState jurisdiction which has fiscal autonomy. A separate line should be
included for all Constituent Entities in the MNE group deemed by the
Reporting MNE not to be resident in any tax jurisdiction for tax purposes.
Where a Constituent Entity is resident in more than one tax jurisdiction, the
applicable tax treaty tie breaker should be applied to determine the tax
jurisdiction of residence. Where no applicable tax treaty exists, the
Constituent Entity should be reported in the tax jurisdiction of the Constituent
Entity’s place of effective management. In the first instance, the place of
effective management should be determined in accordance with the
provisions of Article 4 of the OECD Model Tax Convention and its
accompanying Commentary.
Revenues
In the three columns of the template under the heading Revenues, the
Reporting MNE should report the following information: (i) the sum of
revenues of all the Constituent Entities of the MNE group in the relevant tax
jurisdiction generated from transactions with associated enterprises. Intrajurisdiction related party transactions should not be eliminated; (ii) the sum of
revenues of all the Constituent Entities of the MNE group in the relevant tax
jurisdiction generated from transactions with independent parties; and (iii) the
total of (i) and (ii). Revenues should include revenues from sales of inventory
and properties, services, royalties, interest, premiums, extraordinary income
and any other income amounts (e.g. unrealised gains/ losses). Revenues
should exclude payments received from other Constituent Entities that are
treated as dividends in the payor’s tax jurisdiction.
Profit (Loss) before Income Tax
In the fifth column of the template, the Reporting MNE should report the sum
of the profit (loss) before income tax for all the Constituent Entities resident
for tax purposes in the relevant tax jurisdiction. The profit (loss) before
income tax should include all extraordinary income and expense items.

Income Tax Paid (on Cash Basis)
In the sixth column of the template, the Reporting MNE should report the total
amount of income tax actually paid during the relevant fiscal year by all the
Constituent Entities resident for tax purposes in the relevant tax jurisdiction.
Taxes paid should include cash taxes paid by the Constituent Entity to the
residence tax jurisdiction and to all other tax jurisdictions. Taxes paid should
include withholding taxes paid by other entities (associated enterprises and
independent enterprises) with respect to payments to the Constituent Entity.
Thus, if company A resident in tax jurisdiction A earns interest in tax
jurisdiction B, the tax withheld in tax jurisdiction B should be reported by
company A.
Income Tax Accrued (Current Year)
In the seventh column of the template, the Reporting MNE should report the
sum of the accrued current tax expense recorded on taxable profits or losses
of the year of reporting of all the Constituent Entities resident for tax purposes
in the relevant tax jurisdiction. The current tax expense should reflect only
operations in the current year and should not include deferred taxes or
provisions for uncertain tax liabilities.
Stated Capital
In the eighth column of the template, the Reporting MNE should report the
sum of the stated capital of all the Constituent Entities resident for tax
purposes in the relevant tax jurisdiction. With regard to permanent
establishments, the stated capital should be reported by the legal entity of
which it is a permanent establishment unless there is a defined capital
requirement in the permanent establishment tax jurisdiction for regulatory
purposes.
Accumulated Earnings
In the ninth column of the template, the Reporting MNE should report the
sum of the total accumulated earnings of all the Constituent Entities resident
for tax purposes in the relevant tax jurisdiction as of the end of the year. With
regard to permanent establishments, accumulated earnings should be
reported by the legal entity of which it is a permanent establishment.
Number of Employees
In the tenth column of the template, the Reporting MNE should report the
total number of employees on a full-time equivalent basis of all the
Constituent Entities resident for tax purposes in the relevant tax jurisdiction.
The number of employees may be reported as of the year end, on the basis
of average employment levels for the year, or on any other basis consistently
applied across tax jurisdictions and from year to year. For this purpose,
independent contractors participating in the ordinary operating activities of
the Constituent Entity may be reported as employees. Reasonable rounding
or approximation of the number of employees is permissible, providing that
such rounding or approximation does not materially distort the relative
distribution of employees across the various tax jurisdictions. Consistent
approaches should be applied from year to year and across entities.
9
Tangible Assets other than Cash and Cash Equivalents
In the eleventh column of the template, the Reporting MNE should report the
sum of the net book values of tangible assets of all the Constituent Entities
resident for tax purposes in the relevant tax jurisdiction. With regard to
permanent establishments, assets should be reported by reference to the tax
jurisdiction in which the permanent establishment is situated. Tangible assets
for this purpose do not include cash or cash equivalents, intangibles, or
financial assets.
6.6 The following specific instructions should be followed in completing Table 2
of the CbC Report template:
Constituent Entities Resident in the Tax Jurisdiction
The Reporting MNE should list, on a tax jurisdiction-by-tax jurisdiction basis
and by legal entity name, all the Constituent Entities of the MNE group which
are resident for tax purposes in the relevant tax jurisdiction. As stated above
with regard to permanent establishments, however, the permanent
establishment should be listed by reference to the tax jurisdiction in which it
is situated. The legal entity of which it is a permanent establishment should
be noted (e.g. XYZ Corp – Tax Jurisdiction A PE). With regard to Constituent
Entities deemed not to be resident in any tax jurisdiction for tax purposes, a
separate line should be included, with a further breakdown for each entity
(e.g. partnership with no tax jurisdiction of tax residence).
Tax Jurisdiction of Organisation or Incorporation if Different from Tax
Jurisdiction of Residence
The Reporting MNE should report the name of the tax jurisdiction under
whose laws the Constituent Entity of the MNE is organised or incorporated if
it is different from the tax jurisdiction of residence.
Main Business Activity(ies)
The Reporting MNE should determine the nature of the main business
activity(ies) carried out by the Constituent Entity in the relevant tax jurisdiction,
by ticking one or more of the appropriate boxes.
6.7 The format for preparing CbC Reports is the prevailing CbCR XML Schema
as published on the IRAS CbCR webpage. The Comptroller does not accept
CbC Reports prepared in any other format.
6.8 Further guidance on preparing CbC Reports can be found in the “IRAS
Supplementary Instructions for Preparing CbCR Data File” user guide that is
available on the IRAS CbCR webpage. Reporting Entities may wish to seek
the services of a tax or IT professional or vendor to assist them in collating
and/ or preparing the required data in accordance with the CbCR XML
Schema if they do not have the relevant expertise to do so.

7 Submission of CbC Reports
7.1 From FY 2017, a Reporting Entity that meets the CbCR filing requirements
must submit its CbC Report to the Comptroller within 12 months from the end
of that financial year.

7.2 Reporting Entities can refer to the IRAS CbCR webpage for details on how
to submit CbC Reports to the Comptroller.
8 Penalties for non-compliance
8.1 Penalties may be imposed under Section 105M of the Income Tax Act 1947
for:

Submitting false or misleading information.
9 Contact information
9.1 For enquiries or clarifications on this e-Tax Guide, please email
ct_transfer_pricing@iras.gov.sg.

10 Frequently asked questions
Notification of filing obligation
1. Are the Singapore tax resident constituent entities of a non-Singapore
headquartered MNE group or Singapore tax resident constituent
entities of a Singapore MNE group (apart from the Reporting Entity)
required to provide IRAS with the information stated in paragraph 5.2
of this e-Tax Guide?
No, only the Reporting Entity of a Singapore MNE group that has met the
filing requirements stated in paragraph 3.3 above is required to notify the
Comptroller of its obligation to file a CbC Report and provide the information
stated in paragraph 5.2 of this e-Tax Guide.
Filing requirement
2. What is the definition of consolidated group revenue for the purpose of
determining whether a Singapore MNE group is required to file a CbC
Report?
In determining whether the consolidated group revenue of the MNE is at least
S$1,125 million, all of the revenue that is reflected in the consolidated
financial statements should be used. From FY 2022 onwards, the
consolidated group revenue should include extraordinary income and gains
from investment activities.
For entities that do not reflect the gross amounts with respect to certain
revenue items under applicable accounting rules (e.g. banks may reflect net
interest revenue), the net amount of item(s) considered similar to revenue
should be used to determine if the consolidated group revenue of the MNE
is at least S$1,125 million.
3. For the purpose of the above threshold (whether an MNE is required to
file a CbC Report), should the revenue of associated companies, joint
ventures or partnerships be included as part of the consolidated group
revenue?
The consolidated group revenue of an MNE refers to the revenue figure
disclosed in its consolidated financial statements. Revenue of associated
companies and joint ventures accounted for under the equity method and
partnerships that are not consolidated under applicable accounting rules
should not form part of this figure.

4. An MNE’s consolidated group revenue for FY 2021 exceeded the
   threshold of S$1,125 million, but fell below this threshold in FY 2022. Is
   the MNE required to file a CbC Report for FY 2022?
   Yes, the MNE is required to file a CbC Report for FY 2022 as the requirement
   to file is based on whether the MNE’s consolidated group revenue exceeded
   the threshold in the preceding financial year (i.e. FY 2021).
5. Following from Question 4 above, is the MNE required to file a CbC
   Report for FY 2023?
   The MNE is not required to file a CbC Report for FY 2023 as its consolidated
   group revenue for FY 2022 did not exceed the threshold.
6. How should an MNE’s consolidated group revenue be determined for
   the purposes of applying the S$1,125 million threshold if the preceding
   financial year of the MNE is shorter than 12 months?
   The MNE may determine the group revenue by adjusting the consolidated
   group revenue for the short accounting period to reflect the consolidated
   group revenue that would correspond to a 12-month period. For instance, if
   the accounting period is only six months, the revenue for the six months can
   be multiplied by two to reflect the revenue for a 12-month period. This
   calculated revenue will be used to determine if the MNE’s consolidated group
   revenue in the preceding financial year exceeded the threshold.
   Clarification of terms used in the CbC Report template
   Constituent Entities
   7a. Do associated companies or joint ventures fall within the definition of
   constituent entities?
   As associated companies and joint ventures do not fall within the definition
   of “Constituent Entity” stated in paragraph 6.3 above, they are not considered
   constituent entities of an MNE group.
   7b. If one of the constituent entities of an MNE group (e.g. X Limited in Tax
   Jurisdiction X) was deemed to have a permanent establishment in Tax
   Jurisdiction Y but did not prepare a separate set of financial statements
   for such a permanent establishment, would the deemed permanent
   establishment be a constituent entity?
   The deemed permanent establishment would not be considered a separate
   constituent entity.

However, if the permanent establishment in Tax Jurisdiction Y had prepared
a separate set of financial statements, this deemed permanent establishment
would be treated as a separate constituent entity from X Limited.
7c. What is the treatment of a deemed permanent establishment? How
should it be reflected in a CbC Report?
If the deemed permanent establishment prepared a separate set of financial
statements, it will be regarded as a separate constituent entity. In this case,
financial information relating to the deemed permanent establishment should
be reported under the tax jurisdiction where this deemed permanent
establishment is situated. Following from the example in Question 7(b), the
data relating to the deemed permanent establishment should be reported in
Tax Jurisdiction Y and not in Tax Jurisdiction X.
However, if the deemed permanent establishment did not prepare a separate
set of financial statements, it will be regarded as part of the constituent entity.
In this case, data relating to the deemed permanent establishment should be
reported in the tax jurisdiction of residence of the constituent entity (i.e. Tax
Jurisdiction X).
Period covered by the annual template

8. How should a Reporting MNE reflect the financial information of its
   constituent entities if they have different financial year end (“FYE”)
   from the Reporting MNE? For example, the FYE of Reporting MNE is 31
   December, FYE of Subsidiary A is 30 September, FYE of Subsidiary B
   is 31 March, and FYE of Subsidiary C is 31 December.
   As stated in paragraph 6.4 above, a Reporting MNE has the discretion to
   reflect, on a consistent basis, either one of the following:
   (1) Information for the FYE of constituent entities ending on the same date
   as the FYE of the Reporting MNE, or ending within the 12-month period
   preceding such date.
   In the example given, if the CbC Report is for Reporting MNE’s FYE 31
   December 2022, the CbC Report should include financial information of
   Subsidiary A for the FYE 30 September 2022, Subsidiary B for the FYE
   31 March 2022 and Subsidiary C for the FYE 31 December 2022;
   OR
   (2) Information for all constituent entities reported for the FYE of the
   Reporting MNE (i.e. include financial information of all constituent
   entities for the same period as the Reporting MNE).

In the example given, if the CbC Report relates to the financial period 1
January 2022 to 31 December 2022 for the Reporting MNE, the CbC
Report should include financial information of all constituent entities for
that same period 1 January 2022 to 31 December 2022. This can be
done through directly identifying the financial information of its
subsidiaries for the period 1 January 2022 to 31 December 2022.
Source of data
9a. Does IRAS have any preference on the sources of data used to
complete the CbC Report?
As stated in paragraph 6.4 above, sources of data may include data from the
MNE group’s consolidated reporting packages, separate entity statutory
financial statements, regulatory financial statements or internal management
accounts.
9b. Given the differences in the accounting and tax treatment, basis of
taxation and the tax periods, ‘Revenues’ reported in Table 1 may not be
the same as that in the consolidated financial statements. Is it
necessary for MNEs to do a reconciliation?
IRAS does not require MNEs to do any reconciliation.
9c. What exchange rate should be used to translate the statutory financial
statements of constituent entities to the functional currency of the
Reporting MNE?
The average exchange rate for the reporting year should be used. The MNE
should also state the rate that it used in Table 3.
Revenues
10a. Would ‘Revenues’ include revenue figures of associated companies or
joint ventures?
The term ‘Revenues’ refers to the aggregate sum of revenue figures of all
constituent entities in the same tax jurisdiction. Since associated companies
or joint ventures do not fall within the definition of constituent entities,
revenues of associated companies or joint ventures should not be included.
10b. Would dividends from associated companies constitute ‘Revenues’?
As stated in paragraph 6.5 above, ‘Revenues’ excludes only dividends from
constituent entities. Hence, dividends from associated companies (not
constituent entities) should be included in ‘Revenues’.

10c. Should ‘Revenues’ be reported on a gross or net basis?
Whether ‘Revenues’ is to be reported at gross or net would depend on the
industry practice. For example, the practice in the banking industry may be
to include net (i.e. as opposed to gross) interest income as a revenue item in
the accounts.
10d. Should revenues received from an associated company or joint venture
be reflected as Related Party or Unrelated Party Revenues in Table 1?
As associated companies and joint ventures are not considered constituent
entities of an MNE group, revenues received from them should be reflected
as Unrelated Party Revenues.
10e. How should revenue transactions with a permanent establishment be
accounted for? Are they considered Related or Unrelated Party
Revenues?
They should be reflected as Related Party Revenues, if the permanent
establishment is listed as a separate constituent entity.
Profit (Loss) before Income Tax
11a. At the consolidated financial statements level, profit (loss) before
income tax would include the share of profit of associated companies.
Should the same definition apply for CbCR since only the revenue of
subsidiaries should be included in CbCR?
The term ‘Profit (Loss) before Income Tax’ refers to the aggregate sum (i.e.
not consolidated) of profit (loss) before income tax figures of all constituent
entities in the same tax jurisdiction. Hence, the share of profit of associated
companies would not come into the picture and thus should not be included.
11b. Should dividends be included in ‘Profit (Loss) before Income Tax’?
As dividends from constituent entities are to be excluded from ‘Revenues’,
they should also be excluded from ‘Profit (Loss) before Income Tax’. On the
other hand, dividends from associated companies and third parties are to be
included since they are not constituent entities.
Income Tax Paid (on Cash Basis)
12a. Should income tax paid on dividends from constituent entities be
included in ‘Income Tax Paid (on Cash Basis)’?
As dividends from constituent entities are to be excluded from ‘Revenues’
and ‘Profit (Loss) before Income Tax’, income tax paid on such dividends
(including withholding taxes) should accordingly be excluded from ‘Income Tax Paid (on Cash Basis)’. On the other hand, income tax paid on dividends
from associated companies and third parties are to be included since they
are not constituent entities.
12b. For withholding tax borne by the payer of income, should the income
recipient report it as ‘Income Tax Paid (on Cash Basis)’?
No, as the recipient did not suffer the tax.
12c. Would other forms of taxes (e.g. ‘Financial Tax’ and ‘Turnover Tax’ paid
in Brazil, ‘Fringe Benefit Tax’ in India) be included as ‘Income Tax Paid
(on Cash Basis)’?
Income tax generally refers to corporate income tax paid on a company’s
profit. This is usually the ‘Income Tax’ as captured in the company’s financial
statements and should not include taxes such as value-added tax (“VAT”) or
other business taxes.
12d. Would ‘Income Tax Paid (on Cash Basis)’ include tax paid for past
years? For example, if the taxes paid in FY 2022 include taxes of $3,000
for FY 2019 to FY 2021, should the company include the $3,000 in its
CbC Report for FY 2022?
The Reporting MNE should report the total amount of income tax actually
paid during the relevant fiscal year. As such, in the scenario described, the
company would have to report the $3,000 in the FY 2022 CbC Report under
‘Income Tax Paid (on Cash Basis)’.
12e. Should ‘Income Tax Paid (on Cash Basis)’ be reported as net of tax
refund?
Yes, the figure reported should be net of tax refunds received in the year.
Income Tax Accrued (Current Year)
13a. Should income tax provision be included under ‘Income Tax Accrued
(Current Year)’?
The reporting MNE should report the sum of the accrued current tax expense
recorded on taxable profits or losses for the year of reporting of all the
constituent entities. The current tax expense should reflect only operations in
the current year and should not include deferred taxes or provisions for
uncertain tax liabilities. For example, with reference to the following
disclosure in the financial statements, the ‘Income Tax Accrued (Current
Year)’ to be reported in the CbC Report would be $16 instead of $14.

Accounting disclosure of tax expense $
Current tax expense 16
Deferred tax expense (5)
Under-provision of previous financial year’s income tax expense 3
Income tax expense 14
13b. Should income tax accrued on dividends from constituent entities be
included in ‘Income Tax Accrued (Current Year)’?
As dividends from constituent entities are to be excluded from ‘Revenues’
and ‘Profit (Loss) before Income Tax’, income tax accrued on such dividends
should accordingly be excluded from ‘Income Tax Accrued (Current Year)’.
On the other hand, income tax accrued on dividends from associated
companies and third parties are to be included since they are not constituent
entities.
Stated Capital
14a. Should ‘Stated Capital’ include reserves (e.g. investment revaluation
reserve) and share premium?
This would depend on whether the item forms part of stated capital in the
financial statements in accordance with the applicable accounting rules.
Where the reserves do not form part of stated capital (e.g. it is a separate
line item from stated capital in the financial statements), they should not be
included in ‘Stated Capital’. On the other hand, share premium forms part of
share capital and should be included in ‘Stated Capital’.
14b. Would preference shares or perpetual securities fall within the
definition of ‘Stated Capital’?
‘Stated Capital’ refers to capital as reflected in the financial statements. It
would usually be the ordinary share capital but could also include preference
share capital and perpetual securities.
14c. For branches (i.e. permanent establishments), the term ‘head office
funds’ is normally used instead of ‘capital’ in the financial statements.
How should ‘Stated Capital’ be completed for branches without
regulatory capital?
The amount of stated capital should be reported only by the constituent entity
(and not by the permanent establishment) unless there is a defined capital
requirement for the permanent establishment for regulatory purposes. Hence,
there is no need to state the ‘Stated Capital’ for branches (or permanent
establishments) unless there is a defined capital requirement for the
permanent establishment for regulatory purposes.

14d. How should ‘Stated Capital’ be completed for MNEs with multi-tiered
group structure?
‘Stated Capital’ refers to the sum of the stated capital of all constituent entities
resident for tax purposes in a tax jurisdiction. Hence, MNEs with multi-tiered
group structures should first identify which of their lower-tiered entities are
constituent entities. They should then sum up the stated capital of these
constituent entities according to the tax jurisdictions in which they are
situated, and report these figures accordingly in Table 1.
Accumulated Earnings

How should accumulated earnings of a permanent establishment, for
instance, a branch, be reflected in a CbC Report?
Accumulated earnings of a permanent establishment, e.g. a branch, should
be reported under the tax jurisdiction of the head office, regardless of whether
the profit had been remitted. Therefore, the accumulated earnings for the
branch should be reflected as “0” while the accumulated earnings of the head
office would include its own accumulated earnings and profits from the
branch.
Number of Employees
16a. Does the term ‘Employees’ include main or sub-contractors, part-timers
and contract staff and how should they be reported?
The term ‘Employees’ would include part-timers and contract staff hired on a
fairly long-term or permanent basis. The number of employees should be
reported on a full-time equivalent (“FTE”) basis. It is important to apply this
definition consistently among entities in an MNE group and from year to year.
‘Employees’ could also include main contractors or sub-contractors provided
they are independent and engaged to perform important functions in the
MNEs’ value chain. For example, the FTE of persons engaged to operate an
outsourced call centre should be included but not the FTE of persons
engaged to do office cleaning, unless the MNE is in the cleaning industry.
16b. Would executive or non-executive directors be regarded as
‘Employees’?
Non-executive directors would not qualify as ‘Employees’ since nonexecutive directors do not participate actively in the running of the business
operations. Executive directors on the other hand would qualify as
‘Employees’.

16c. Would a consultant or freelancer be regarded as an ‘Employee’?
Consultants and freelancers are normally engaged on a short-term basis.
Hence, they should not be considered ‘Employees’. However, consultants
may be regarded as ‘Employees’ if they are engaged on a fairly long-term or
permanent basis.
16d. Should ‘Number of Employees’ be based on the payroll and is there any
cut-off date to report it?
Companies can choose their source of employee data as long as they use
the same sources of data from year to year.
Similarly, they can choose the cut-off date that best reflects their position for
that reporting year. This is provided they use the same cut-off date from year
to year.
Tangible Assets other than Cash and Cash Equivalents

What is the definition of ‘Main Business Activity(ies)’?
This refers to the functions conducted by business entities to generate the
main sources of revenue stated in Table 1. Usually, these business activities
are described in the financial statements.

Would ‘Tangible Assets’ include trade receivables, properties,
inventories and investments?
The term ‘Tangible Assets’ refers to physical hard assets. Therefore,
‘Tangible Assets’ includes inventories, property, plant and equipment but
excludes trade receivables (i.e. treated as financial assets under FRS 32)
and investments (i.e. can be treated as financial assets under FRS 32 or cash
and cash equivalents under IAS/ FRS 7 for short-term investments).
Completing the CbC Report template

Should transactions between related parties in the same tax jurisdiction
be eliminated for the purpose of completing Table 1?
Transactions between related parties in the same tax jurisdiction should not
be eliminated when preparing Table 1.
As stated in paragraph 4.3 above, the data for each tax jurisdiction should be
presented as an aggregation (as opposed to a consolidation) of the
requested information from all the constituent entities that are resident in that
tax jurisdiction.

20. How should business activities relating to shipping, hospitality or
    property development be reflected in Table 2?
    Companies should reflect such activities under the column ‘Other’ in Table 2
    and provide specific details of the activities in Table 3.
21. How should an MNE complete Table 2 if its main business activity was
    to provide services, and the same services were provided to both
    related and unrelated parties?
    The MNE should reflect its main business activity as ‘Provision of Services
    to Unrelated Parties’.
22. What is the extent of details required for Table 3?
    The following information should be disclosed in Table 3:

• A brief description of the sources of data used to prepare the CbC
  Report. If there was a change in the source of data used as compared
  to the previous year, the reasons for the change and its consequences
  should also be explained;
• Where statutory financial statements are used as the basis for reporting,
  the average exchange rate(s) used to translate amounts to the stated
  functional currency of the Reporting Entity;
• Explanations for changes in the way of reporting from previous years, if
  applicable.
  In addition to the above, companies are free to provide any additional
  information which they consider relevant and useful to interpret and
  understand the data disclosed in the CbC Report.

20. Can rounded figures be reported in the CbC Report?
    Companies can report rounded figures in their CbC Report if the source data
    from which those amounts have been obtained consists of rounded figures.
    Companies should ensure that the rounding does not have a material impact
    in terms of understanding the CbC Report. When rounding off to the nearest
    thousand, companies would still have to show the figures in full. For example,
    if the rounded figure is S$1,126,000, it should be entered in the CbC Report
    as S$1,126,000 and not S$1,126.
    Others
21. What will the information provided in a CbC Report be used for?
    The 2015 Final Report on BEPS Action 13 sets out three permitted uses for
    information contained in CbC Reports, namely:

• To assess high-level transfer pricing risk;
• To assess other BEPS-related risks; and
• For economics and statistical analysis.

IRAS will use the information contained in CbC Reports in accordance with
these permitted uses.

25. How would IRAS ensure that jurisdictions that it exchanges CbC
    Reports with use the reports in an appropriate manner and have put in
    place sufficient protections to safeguard the confidentially of the CbCR
    data?
    IRAS will enter into agreements with jurisdictions for exchange of CbC
    Reports only after establishing that the jurisdictions have a strong rule of law
    and are able to ensure confidentiality of the information exchanged and
    prevent its unauthorised use. IRAS would suspend or cease the exchange of
    information with any jurisdiction which has been known to have misused the
    information or which is in breach of this confidentiality obligation.
26. Does Singapore provide for surrogate filing for non-Singapore
    headquartered MNE groups?
    No, Singapore does not see a need to provide for surrogate filing for foreign
    MNE groups. Only Singapore MNE groups are required to submit CbC
    Reports to IRAS.
27. Will Singapore impose secondary mechanisms on non-Singapore
    headquartered MNE groups?
    Singapore intends to follow the OECD guidelines and to provide for
    secondary mechanism on Singapore subsidiaries of foreign MNEs in our
    CbCR legislation. IRAS will monitor developments and assess if there is a
    need to trigger secondary mechanism.
    Nevertheless, Singapore expects MNEs to be co-operative in providing CbC
    Reports to their home jurisdictions, and the reports could then be exchanged
    under CbCR AEOI agreements between their home jurisdictions and
    Singapore.

11 Updates and amendments
Date of
amendment Amendments made
1 11 Jul 2017 IRAS has enhanced the guidance by providing
additional FAQs (i.e. section 8) as follows:

• Inserted questions 2, 5, 11 and 19d
  Other amendments:
• Deleted footnote 1 as Singapore has enacted
  legislation for CbCR in the Income Tax Act.
  2 7 Aug 2018 IRAS amended question 11 of the FAQ.
  3 31 Oct 2022 Main amendments:
• Amended sections 1 and 3 to incorporate the
  obligations of a Singapore MNE group under
  Singapore’s notification requirement
• Inserted a new section 5 on Singapore’s
  notification requirement
• Inserted paragraphs 6.7 and 6.8 on the
  preparation of CbC Reports in CbCR XML
  Schema format
• Amended section 7 on the submission of CbC
  reports to IRAS
• Inserted a new section 8 on penalties for noncompliance
• Enhanced the FAQs in section 10:
  o Inserted new questions 1, 12a, 13b, 14a
  and 15
  o Amended questions 2*, 4, 5, 8, 12d, 13a,
  22 and 27
  o Deleted questions on the term “Revenues”
  in the CbC Report and penalties
  (questions 16a and 26 in the third edition
  of the e-Tax Guide)
• 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