Introduction
The Inland Revenue Authority of Singapore (“IRAS”) has published updated guidance on amendments to the Common Reporting Standard (“CRS”), introducing expanded obligations for Reporting Singaporean Financial Institutions (“RSGFIs”). The amendments cover three broad areas, a wider scope of reportable products and accounts, additional data fields required in each CRS submission, and more stringent due diligence standards.
Overview of Amendments to the CRS
IRAS has outlined three (3) key changes that RSGFIs should take note of.
| Area | Additional Information under the Amended CRS | Important Considerations/Required Actions |
|---|---|---|
| Expanded Scope | The following products are now in-scope/reportable:
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| More data fields required per account | Roles of Controlling Persons and Equity Interest Holders Capture and report the specific role of each Controlling Person linked to an Entity Account Holder (e.g. ownership, control through other means); for Investment Entities that are legal arrangement (i.e. trusts), the roles of Equity Interest Holders must be reported. Self-Certification Status Indicate whether a valid self-certification has been obtained for each Account Holder and, where applicable, each Controlling Person. Financial Account Information Indicate whether it is a joint account (and number of joint Account Holders), the account type (e.g. depository, custodial, insurance), and whether it is a new or pre-existing account. |
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| Tighter standards for account reviews | Additional Due Diligence measures:
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Summary
Following the OECD’s first comprehensive review of the CRS, amendments published in 2023 aim to ensure the framework remains effective in addressing evolving financial products and market developments. The amended CRS expands the scope of reportable financial accounts and assets to include certain digital financial products such as SEMPs. In addition, RSGFIs will be required to collect and report additional information regarding the roles of Controlling Persons and Equity Interest Holders, self-certification status, and enhanced account-level details. The amendments also introduce strengthened due diligence requirements to improve the accuracy and consistency of CRS reporting across jurisdictions. Key changes include: the removal of tax residency tiebreaker rules for dual-resident Account Holders, enhanced look-through requirements for Controlling Persons, consideration of citizenship- or residence-by-investment risks, and stricter mandatory expectations for obtaining valid self-certifications. As a result, RSGFIs should review their product offerings, client populations, onboarding and due diligence procedures, reporting systems, and internal controls to ensure compliance with the expanded CRS requirements and reporting obligations.
How We Can Help
As a compliance solutions advisor and funds specialist, we also partner with well-known tax advisors, to assist you in understanding the latest market developments and recommendations to help your institution meet these regulatory requirements. Feel free to reach out to us for non-obligatory discussion.
¹ Digital currency issued directly by a central bank (e.g. a digital Singapore dollar issued by MAS)
² A digital store of value pegged to one currency, such as an e-wallet balance or prepaid card, that is issued upon receipt of funds and accepted as payment by third parties.
³ A tax treaty provision that assigns a single country of tax residence, for treaty purposes, when a taxpayer qualifies as resident in two countries.
⁴ CBI refers to a program that grants citizenship in exchange for a qualifying investment or financial contribution.
⁵ RBI refers to a program that grants residence rights in exchange for a qualifying investment or financial contribution.
