The Inland Revenue Authority of Singapore released a guide on country-by-country (CbC) reporting that requires multinational enterprise groups with a Singapore-based ultimate parent company to compile information on the group’s profits from worldwide operations. The issuance of the CbC reporting guide follows Singapore’s decision to participate in the inclusive framework under OECD’s base erosion and profit shifting (BEPS) project.
CbC reporting will only apply to multinational enterprise (MNE) groups when:
When a Singapore entity is not the ultimate parent company, it will not be required to prepare a CbC report, given that the parent company may be responsible for filing a CbC report in its home country. However, a Singapore company may still be involved in the preparation of the CbC report, by providing the required information to the ultimate parent company.
The CbC reporting guide establishes the format of the CbC report; clarifies the definitions of certain key concepts and terms; provides guidance on the CbC report completion; clarifies that a non-Singapore headquartered MNE group is not required to submit a CbC report to the Singapore tax authorities; and clarifies that there is no intention to implement a secondary mechanism for non-Singapore headquartered MNE groups.
The CbC report is intended to supplement a taxpayer's transfer pricing documentation, and cannot be used as a substitute for the transfer pricing documentation. Details on the mode for transmitting the CbC report are expected to be provided at a later date.
Read an October 2016 report [PDF 113 KB] prepared by the KPMG member firm in Singapore: Overview of Country-by-Country Reporting in Singapore
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