The Common Reporting Standard in Singapore

Read the PDF edition (1 page)

Singapore implemented the CRS through the Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) Regulations 2016, with due diligence from 1 January 2017 and first exchanges in September 2018. Reporting Singapore financial institutions identify account holders who are tax-resident in a reportable jurisdiction, collect self-certifications, report to IRAS by 31 May each year and IRAS exchanges with partner jurisdictions by September.¹ Switzerland is a CRS partner of Singapore under the Multilateral Competent Authority Agreement. The two countries have exchanged account data on each other's residents since 2018.

A digital-asset business in Singapore is a reporting financial institution under the CRS if it is a custodial institution, a depository institution, an investment entity or a specified insurance company. A DPT custodian that holds tokens for customers has argued since 2017 that it is not a custodial institution because tokens are not "financial assets" as the CRS defines them. The OECD conceded that most crypto assets fell outside the definition. That gap was the reason for CARF. The amended CRS, which Singapore applies from the same date as CARF, extends the definition of financial assets to specified electronic money products and central bank digital currencies and brings indirect crypto exposure through derivatives and investment entities within CRS reporting.² A Singapore fund that invests in tokens is an investment entity for CRS purposes already. Its investors' interests have been reportable since 2017, a point family offices with foreign members sometimes overlook.

Notes

Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) Regulations 2016; Income Tax Act 1947, s. 105K ff. (international tax compliance agreements). IRAS, CRS Overview, filing deadline of 31 May. ↩
OECD, Amendments to the Common Reporting Standard, 2022 (inclusion of specified electronic money products and CBDCs as financial assets; reporting of indirect investment in crypto-assets through investment entities). ↩

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 directly at [email protected] 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. As a Singapore law practice, KGP Legal LLC is authorised under the Legal Profession Act 1966 to advise on Singapore law and to represent clients before the Singapore courts; foreign law practices with an office in Singapore are, as a rule, not permitted to do either. 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 legal, tax and fiduciary services in Switzerland, see helveticaregister.com.