FATCA

Read the PDF edition (1 page)

Both hubs apply the United States Foreign Account Tax Compliance Act through intergovernmental agreements. Singapore has a Model 1 IGA, signed in 2014 and replaced by a reciprocal Model 1 IGA signed on 13 November 2018, under which Singapore financial institutions report US account holders to IRAS, which transmits the data to the Internal Revenue Service.¹ Switzerland has operated a Model 2 IGA since 2014, under which Swiss institutions report directly to the IRS with consent and group requests cover the rest. It signed a Model 1 agreement on 27 June 2024 that is expected to take effect from 2027 after ratification.²

For digital-asset businesses FATCA matters because the United States is not a CARF participant in the ordinary sense. It has announced that it will implement its own broker reporting under section 6045 of the Internal Revenue Code and exchange on a reciprocal basis only with jurisdictions that meet its conditions. A Singapore or Swiss exchange with US customers is therefore within FATCA as a financial institution to the extent its services fit the FATCA definitions. For custodial institutions holding crypto that raises the same definitional problem as the CRS. The exchange must in any event comply with the US broker rules if it is a broker for US persons. Most Singapore and Swiss exchanges have resolved the problem by refusing US customers. The AML onboarding described in Part L, Chapter II screens for US indicia for that reason.

Notes

Agreement between the Government of the Republic of Singapore and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA, signed 13 November 2018 (reciprocal Model 1), in force 1 January 2021; Income Tax (International Tax Compliance Agreements) (United States of America) Regulations 2020. ↩
Agreement between Switzerland and the United States on cooperation to facilitate the implementation of FATCA (Model 1), signed 27 June 2024; Federal Council dispatch for ratification. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

English

Contact

Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me if you need any further information.

Get in touch →

Articles and Insights

Setting up or expanding in Singapore?

SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.