As promised in July, Singapore provided details regarding changes to FATCA reporting requirements. The changes take effect as of April 1, 2020.

End of IDES

Despite being a Model 1 IGA jurisdiction, Singapore has required Reporting Singapore Financial Institutions (SGFIs) to submit electronic FATCA reporting through the U.S. Internal Revenue Service’s (IRS) International Data Exchange System (“IDES”). Effective April 1, 2020, all Reporting SGFIs must submit all electronic FATCA returns through the “Submit CRS or FATCA Return” e-Service at IRAS’ myTax Portal.

The switch from IDES to myTaxPortal includes not just Y2019 submissions but all amended, corrected or void FATCA returns related to prior years.

It is necessary under IDES to obtain a digital certificate prior to beginning the IDES enrollment process. The certificate must be obtained from an IRS approved certificate authority. Because SGFIs will no longer use IDES, it will not be necessary to have a valid certificate as of April 1, 2020.

Nil Reporting

Singapore requires SGFIs that did not maintain any US Reportable Accounts during the year and did not make payment to any Non-Participating FI to provide a nil return. Currently, an SGFI may do so either by:

• Preparing a FATCA reporting packet and transmitting it through IDES; or

• Completing a paper FATCA Nil Return and mailing it the Inland Revenue Authority of Singapore (IRAS).

Effective April 1, 2020, all nil returns must be submitted electronically to IRAS via the “Submit CRS or FATCA Return” e-Service at IRAS’ myTax Portal. Paper returns will not be accepted. However, an SGFI does not need to prepare and submit a nil return in XML format. Instead, it can indicate that it is submitting “a return with no data” when it uses myTax Portal.

Changes to Schema

Not surprisingly, the shift from IDES to myTax Portal has resulted in some XML schema changes. IRAS issued the IRAS Supplementary XML Schema User Guide for Preparing the FATCA Reporting Data File to assist SGFIs in understanding the changes. The guide provides instructions on how the information for certain data elements must be presented for the purpose of FATCA reporting to IRAS via myTax Portal.

FATCA Registration

Many SGFIs have already registered in myTax Portal for CRS purposes. It will also be necessary to provide IRAS with a SGFI’s FATCA information via myTax Portal. This can be accomplished through the “Apply for CRS Registration” e-Service.

Reporting SGFIs that do not provide their FATCA registration information will be unable to file their FATCA returns via myTax Portal.

Plan ahead on myTax Portal registration because IRAS indicated it will take about three weeks to process. Once IRAS processes the application it will send an e-mail to the Point of Contact (or individual trustee) to inform her of the application’s outcome.

The Singapore CRS Regulations require an entity that becomes a Reporting SGFI at any time during a calendar year to submit an application to register with IRAS by March 31 of the following year. I recommend you follow this schedule for FATCA registration as well.

Weekly Maintenance Hours

Please note that Singapore’s myTax Portal will not be available during the following times (Singapore time):

• 2 AM – 6 AM on Wednesdays

• 2 AM – 8:30 AM on Sundays

For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.

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