Income Tax (International Tax Compliance Agreements) (Crypto‑Asset Reporting Framework) Regulations 2026

These Regulations are the Income Tax (International Tax Compliance Agreements) (Crypto‑Asset Reporting Framework) Regulations 2026 and come into operation on 1 January 2027.

These Regulations implement Part 1 of the International Standards for Automatic Exchange of Information in Tax Matters pursuant to the Crypto‑Asset Reporting Framework developed and published by the Organisation for Economic Co‑operation and Development (called in these Regulations the CARF), for the purpose of giving effect to any CARF agreement that is declared as an international tax compliance agreement under section 105K(1) of the Act.

The CARF is set out in the Schedule.

These Regulations implement Part 1 of the International Standards for Automatic Exchange of Information in Tax Matters pursuant to the Crypto‑Asset Reporting Framework developed and published by the Organisation for Economic Co‑operation and Development (called in these Regulations the CARF), for the purpose of giving effect to any CARF agreement that is declared as an international tax compliance agreement under section 105K(1) of the Act.

The CARF is set out in the Schedule.

In these Regulations —

“active entity” has the same meaning as “Active Entity” in subparagraph D(11) of Section IV of the CARF;

“AML/KYC procedures” has the same meaning as “AML/KYC Procedures” in subparagraph F(2) of Section IV of the CARF;

“controlling persons” has the same meaning as “Controlling Persons” in subparagraph D(10) of Section IV of the CARF;

“crypto‑asset user” has the same meaning as “Crypto‑Asset User” in subparagraph D(2) of Section IV of the CARF;

“entity” has the same meaning as “Entity” in subparagraph F(3) of Section IV of the CARF;

“entity crypto‑asset user” has the same meaning as “Entity Crypto‑Asset User” in subparagraph D(5) of Section IV of the CARF;

“excluded person” has the same meaning as “Excluded Person” in subparagraph E(1) of Section IV of the CARF;

“individual crypto‑asset user” has the same meaning as “Individual Crypto‑Asset User” in subparagraph D(3) of Section IV of the CARF;

“IRAS Internet website” means the Internet website of the Inland Revenue Authority of Singapore at https://www.iras.gov.sg;

“pre‑existing entity crypto‑asset user” has the same meaning as “Preexisting Entity Crypto‑Asset User” in subparagraph D(6) of Section IV of the CARF;

“pre‑existing individual crypto‑asset user” has the same meaning as “Preexisting Individual Crypto‑Asset User” in subparagraph D(4) of Section IV of the CARF;

“relevant transaction” has the same meaning as “Relevant Transaction” in subparagraph C(1) of Section IV of the CARF;

“reportable person” has the same meaning as “Reportable Person” in subparagraph D(7) of Section IV of the CARF;

“reportable user” has the same meaning as “Reportable User” in subparagraph D(1) of Section IV of the CARF.

In interpreting these Regulations, recourse is to be had to the CARF read with the Commentaries on the Crypto‑Asset Reporting Framework as at 8 June 2023, which are developed and published by the Organisation for Economic Co‑operation and Development, and available on the IRAS Internet website.

For the purposes of regulations 5, 10, 11(3) and 12(1) and (6), Sections I to IV of the CARF are modified by paragraphs (2) to (6).

For the purpose of paragraph A of Section II of the CARF, the appropriate reporting period mentioned in that provision is a period of 12 months.

In subparagraphs A(1) and B(1)(a) of Section III of the CARF, the effective date mentioned in those provisions is 1 January 2027.

In subparagraphs D(4) and (6) of Section IV of the CARF, the reference to a date is to 31 December 2026. (5) In Sections I and IV of the CARF, “Singapore” is inserted in each placeholder for the jurisdiction.

In Sections I and IV of the CARF, a reference to “Partner Jurisdiction” is to a jurisdiction that is described as one on the IRAS Internet website.

For the purposes of regulations 5, 10, 11(3) and 12(1) and (6), Sections I to IV of the CARF are modified by paragraphs (2) to (6).

For the purpose of paragraph A of Section II of the CARF, the appropriate reporting period mentioned in that provision is a period of 12 months.

In subparagraphs A(1) and B(1)(a) of Section III of the CARF, the effective date mentioned in those provisions is 1 January 2027.

In subparagraphs D(4) and (6) of Section IV of the CARF, the reference to a date is to 31 December 2026.

In Sections I and IV of the CARF, “Singapore” is inserted in each placeholder for the jurisdiction.

In Sections I and IV of the CARF, a reference to “Partner Jurisdiction” is to a jurisdiction that is described as one on the IRAS Internet website.

In these Regulations, “reporting Singaporean crypto‑asset service provider” means a reporting crypto‑asset service provider —

that is an entity or individual resident in Singapore for a tax purpose;

that is an entity that —

is incorporated or registered under the laws of Singapore; and (ii)is either a legal person or under a duty to file a return to the Comptroller with respect to its income under the Act;

that is an entity managed from Singapore;

that is an entity or individual that has a regular place of business in Singapore; or

that has a branch in Singapore through which relevant transactions are effectuated,and that is not exempt under paragraph C, D, E, F or G of Section I of the CARF (as modified by regulation 4) from the reporting and due diligence requirements in Sections II and III of the CARF, as modified by regulation 4.

In these Regulations, a person’s residence for a tax purpose is —

if the person is an individual — the jurisdiction in which the person is resident under the tax laws of the jurisdiction; or

if the person is an entity —

the jurisdiction in which the person is resident under the tax laws of the jurisdiction; or

if the person is not resident in any jurisdiction under the tax laws of any jurisdiction, the jurisdiction in which the person has its effective management.