A CRS Compliance Program for Fiduciaries (Singaporean Edition)

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The Inland Revenue Authority of Singapore (IRAS) directs all Singaporean Financial Institutions (SGFIs), including trustees on behalf of SGFI trusts, to implement a robust compliance program supported by policies and procedures that ensure full compliance with CRS in Singapore. Non-compliance with CRS obligations is an offence under section 105M(1) of the Income Tax Act, which may lead to fines and/or imprisonment. Pursuant to the requirements in the Singaporean CRS legislation and other sources of applicable guidance, this document sets out a CRS Compliance Program for fiduciaries connected to Singaporean private wealth management structures. It is, however, readily adaptable to other jurisdictions and types of FIs.

Description

The Inland Revenue Authority of Singapore (IRAS) directs all Singaporean Financial Institutions (SGFIs), including trustees on behalf of SGFI trusts, to implement a robust compliance program supported by policies and procedures that ensure full compliance with CRS in Singapore.

Pursuant to Regulation 14 of the Singaporean CRS Law, SGFIs must document the process adopted to classify their Financial Account Holders and Controlling Persons and the information collected in the course of this process.

Pursuant to the requirements in the Singaporean CRS legislation and other sources of applicable guidance, this document sets out a CRS Compliance Program for fiduciaries connected to Singaporean private wealth management structures.

It is, however, readily adaptable to other jurisdictions and types of FIs.

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This resource covers:

  • Determination of the applicable jurisdiction and the rules governing an entity’s CRS status;
  • Entity classification, registration and delegation;
  • Identification, due diligence and monitoring of CRS Account Holders andControlling Persons; and
  • Preparation, registration and submission of CRS account reporting.

Caution

Non-compliance with CRS obligations – involving documentation, registration and reporting – is an offence under section 105M(1) of the Income Tax Act, which may lead to fines and/or imprisonment.

IRAS will conduct off- and on-site audits of registered SGFI compliance programs and of non-registered entities that present a higher likelihood of non-compliance.