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  • Elizabeth A. McMorrow

CRS & FATCA: Singapore Sub-Fund Deregistration & Service Provider Limitations

The Inland Revenue Authority of Singapore (IRAS) issued a reminder to financial institutions that an entity that is or becomes a Reporting Singapore-based Financial Institution (SGFI) at any time between January 1, 2017 and December 31, 2017 must apply for Singapore Common Reporting Standard (CRS) registration by March 31, 2018.

IRAS also announced limitations on third-party reporting services and sub-fund FATCA deregistration requirements.

Service Provider Limitations

A Reporting SGFI may not use a third-party service provider to submit its CRS return in 2018.

Singapore’s Apply for CRS Registration e-Service (e-Service) allows a Reporting SGFI to submit an application for CRS registration. The e-Service primarily caters to SGFIs and their staff/representatives who are based in Singapore.

A third-party service provider may prepare the CRS Return for the SGFI and provide it to its SGFI client to submit the CRS Return itself to the IRAS.

Although a company that is not domiciled in Singapore will not be able to submit a CRS Return on behalf of a Reporting SGFI in 2018, the IRAS e-Services will be enhanced to allow Reporting SGFIs to authorize their staff or third parties as users who can access the e-Services and transact with IRAS on the Reporting SGFI’s behalf.

New GIIN Requirement

Under the Foreign Account Tax Compliance Act, a sub-fund may use its umbrella fund’s GIIN (Global Intermediary Identification Number) or the sub-fund may obtain its own GIIN. This option is not available for SGFI CRS registration.

SGFI CRS registration must be done at the umbrella fund level. The SGFI FATCA registration information must also be the umbrella fund’s information including the umbrella fund’s GIIN.

If a sub-fund currently has its own GIIN, the IRAS requires that the sub-fund FATCA registration be cancelled once the umbrella fund has been issued its FATCA GIIN.

Registration for New SGFIs

An entity that becomes a Reporting SGFI between January 1, 2018 and December 31, 2018 will have to apply to register with IRAS by March 31, 2019. Likewise, any entity that becomes a Reporting SGFI during a calendar year must submit an application to register with IRAS by March 31 of the following year.

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