Singapore legislation
Regulation 4
of Income Tax (International Tax Compliance Agreements) (Country-By-Country Reporting) Regulations 2018
Regulation 4
Obligation of ultimate parent entity of MNE group to submit country‑by‑country report
Subregulation 1
Subject to regulation 5, where —
a Type A group or Type B group is an MNE group for any of its accounting periods; and
its ultimate parent entity is resident in Singapore,its ultimate parent entity must submit to the Comptroller or an authorised person a country‑by‑country report for that accounting period for all constituent entities of the MNE group.
Subregulation 1A
The ultimate parent entity must submit to the Comptroller or an authorised person a notice in accordance with paragraph (1B) that it is an entity that has to submit a country‑by‑country report under paragraph (1).
Subregulation 1B
The notice must be —
submitted for each accounting period in the form and manner determined by the Comptroller; and
submitted no later than 3 months after the end of the accounting period, or such later time as the Comptroller may permit.
Subregulation 1C
Paragraph (1A) applies to a country‑by‑country report for each accounting period that begins on or after 1 January 2022.
Subregulation 1D
To avoid doubt, paragraph (1A) does not apply to an ultimate parent entity to which the Comptroller has given a written notice under regulation 5(2)(a) that it need not submit a country‑by‑country report for that accounting period.
Subregulation 2
The ultimate parent entity must submit the country‑by‑country report to the Comptroller or an authorised person no later than 12 months after the end of the accounting period, or such later time as the Comptroller may permit.
Subregulation 3
The ultimate parent entity must keep and retain in safe custody all records that it uses to prepare a country‑by‑country report for a period of 5 years after the end of the accounting period.
Subregulation 4
A requirement under paragraph (1), (1A) or (2) is a requirement under section 105M(1)(b) of the Act, the failure or neglect to comply with which (if such failure or neglect is without reasonable excuse) is an offence under section 105M(1) of the Act.
Subregulation 5
A requirement under paragraph (3) is a requirement the failure or neglect to comply with which (if such failure or neglect is without reasonable excuse) is an offence under section 105M(1B) of the Act.