What this agreement does
The supplied 26-page text alternates equally authentic English and French versions. It establishes a multilateral framework for bilateral automatic exchanges under the Convention on Mutual Administrative Assistance in Tax Matters. A signatory’s Convention must be in force and effect before its first exchange, and domestic law must implement reporting and due diligence consistent with CRS. This is the framework agreement, not a completed Singapore partner list or a financial institution’s filing instruction.
Section 1: jurisdictions and financial institutions
A jurisdiction is a signing country or territory for which the Convention is in force and effect. Competent authorities are those in the Convention’s Annex B. A jurisdiction financial institution includes resident institutions except overseas branches, plus local branches of foreign institutions. Reporting institutions exclude non-reporting institutions. Reportable accounts include accounts of another jurisdiction’s reportable persons and passive NFEs with reportable controlling persons, identified through CRS due diligence.
Definitions and an agreement in effect
An agreement is in effect between two authorities only when they intend to exchange with each other and meet section 7 conditions. Annex E records active relationships. Undefined capitalised terms follow domestic meanings consistent with CRS; other undefined terms normally follow the applying jurisdiction’s law, with tax-law meanings taking priority over other domestic laws. The preamble also anticipates domestic updates reflecting later CRS amendments.
Section 2: annual exchange and non-reciprocity
Each authority annually exchanges the specified information automatically with authorities for which the agreement is effective. Jurisdictions listed in Annex A send information but do not receive it; others receive, and do not send to those non-reciprocal jurisdictions. The blank Annex A in this document supplies no actual jurisdiction names, so it cannot determine a particular country’s status.
Identity and account information exchanged
Data include each reportable holder’s name, address, tax identification numbers and, for individuals, date and place of birth. For entities with reportable controlling persons, exchange entity identity and the controlling persons’ corresponding details. Also include account number or equivalent, reporting institution name and identifier, year-end balance or value including insurance cash or surrender value, and closure where the account closed during the period.
Income and proceeds by account type
Custodial accounts include gross interest, dividends and other asset income, plus gross sales or redemption proceeds where the institution acted as custodian, broker, nominee or agent. Depository accounts report gross interest. Other accounts report gross amounts paid or credited where the institution is the obligor or debtor, including redemption payments. These are gross reporting amounts, not necessarily the account holder’s taxable net profit.
Section 3: timing, currency and transmission
Payment amounts and character can follow the exchanging jurisdiction’s tax-law principles, and every amount identifies its currency. Exchanges begin for Annex F years and occur within nine months after the calendar-year end, only where both authorities have an effective relationship and compatible reporting law for that year. Authorities use the CRS XML schema and agree transmission and encryption methods recorded in Annex B. This deadline governs inter-authority exchange, not an institution’s domestic submission date.
Sections 4 and 5: corrections and safeguards
An authority believing that errors or institutional non-compliance caused incorrect or incomplete reporting notifies the other authority, which takes appropriate domestic-law measures. Exchanged data remain protected by Convention confidentiality and permitted-use limits, plus supplying-authority personal-data safeguards listed in Annex C. A confidentiality breach or safeguard failure must immediately be notified to the Secretariat with sanctions and remedies; the Secretariat informs authorities with effective relationships.
Section 6: consultation and amendment
Implementation or interpretation difficulties can lead to consultation among authorities. Resulting measures are communicated through the Secretariat to all authorities, including non-participants as appropriate. Amendments require consensus in writing by all authorities for which the agreement is in effect. Unless otherwise agreed, they take effect on the first day of the month after a one-month period following the last signature.
Section 7: notification and activation
An authority notifies the Secretariat of implementing laws and relevant dates; non-reciprocal status; transmission and encryption methods; personal-data protections; adequate confidentiality measures with a completed questionnaire; and intended exchange partners. Later changes must be notified promptly. A bilateral relationship starts on the later of the second complete notification naming the other jurisdiction and, where applicable, the Convention becoming effective for both. The Secretariat publishes signatures, effective relationships and specified law/date and reciprocity information; other notification material is available to signatories on written request.
Suspension and termination
Written notice to a partner can suspend exchanges immediately for significant non-compliance, including confidentiality failures, inadequate or late information, or institution/account exclusions that frustrate CRS. An authority may terminate all participation or one relationship by notice to the Secretariat, effective on the first day of the month after twelve months from notice. Previously received information remains confidential and governed by the Convention after termination.
Section 8 and the six annex templates
The Secretariat distributes notifications and new-signatory notices. Administration costs are shared equally annually, except qualifying countries exempt under the coordinating body’s procedure rules. Annexes A–E are uncompleted templates for non-reciprocal jurisdictions, transmission, data safeguards, confidentiality questionnaire and effective relationships. Annex F likewise leaves dates and years blank for new accounts and existing individual high-value, low-value and entity accounts. These placeholders explain the required structure and cannot be replaced with assumed Singapore dates.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗