The 2016 agreement and its treaty basis
This eight-page bilateral agreement was concluded on 22 November 2016 and entered into force and effect on 31 January 2017. It relies on Article 26 of the Singapore–Finland double taxation agreement signed on 7 June 2002, as amended by the 16 November 2009 protocol; Article 25 permits agreement on the scope and arrangements. These are the document’s historical dates, rather than a fresh confirmation of today’s exchange-partner status.
Section 1: jurisdictions and authorities
Finland includes the Republic and adjacent maritime areas where its internationally recognised rights over seabed, subsoil, waters and natural resources may be exercised. Its competent authority is the Ministry of Finance, an authorised representative or an authority designated by the Ministry. Singapore’s is the Minister for Finance or an authorised representative.
Institutions, residence and controlling persons
Resident financial institutions exclude their foreign branches, while local branches of foreign institutions are included. Reporting institutions are those not classified as non-reporting. Reportable accounts are identified through CRS due diligence and include passive non-financial entities whose controlling persons are reportable residents of the partner jurisdiction. Tax residence, including relevant deceased estates, determines the connection; citizenship alone is not the test. Finnish TIN means its taxpayer identifier, and Singapore uses its tax reference number.
Section 2: identity and account information
Exchange the holder’s name, address, TINs and date of birth for individuals. For an entity with reportable controlling persons, exchange entity details and the corresponding identity information for those persons. This text specifies date of birth without a separate place-of-birth field. Include account number or equivalent, reporting institution name and identifier, year-end balance or value and, where closed, the closure of the account. Cash-value insurance and annuity values are included.
Income categories
Custodial accounts report gross interest, dividends and other asset income, together with gross financial-asset sale or redemption proceeds where the institution acts as custodian, broker, nominee or agent. Depository accounts report gross interest. Other accounts report amounts paid or credited where the institution is obligor or debtor, including redemption payments. These categories concern gross reported amounts, not a calculation of taxable profit.
Section 3: first exchanges and the Singapore exception
Exchange starts with 2017 information, within nine months of calendar-year end, provided both jurisdictions have matching legislation for that year. Singapore’s custodial gross sale/redemption proceeds are excluded for 2017 and included from 2018 onwards; that exception is expressly Singapore-specific. Identify each amount’s currency, use the CRS XML schema and agree encrypted transmission methods. Payment characterisation may follow the sending jurisdiction’s tax principles.
Sections 4 and 5: correcting errors and protecting data
An authority alerts its counterpart to suspected reporting errors or due-diligence non-compliance, and the notified authority uses its domestic powers to address them. DTA confidentiality, permitted-use restrictions and any required supplying-authority personal-data safeguards apply. Confidentiality breaches, failed safeguards and resulting sanctions or remedies must be notified immediately.
Section 6: interpretation and amendments
Either authority may request consultations to resolve implementation or interpretation problems. Amendments require written agreement. Unless otherwise agreed, the amendment takes effect on the first day of the month following one month after the later signature or the later notification for that written agreement.
Section 7: all five commencement notifications
Each authority must confirm implementing laws and relevant existing/new-account and due-diligence dates; transmission and encryption methods; required personal-data safeguards; adequate confidentiality measures with the completed questionnaire; and ability to comply with the other authority’s safeguards. The agreement takes effect on the later notification. Subsequent changes must be notified promptly.
Suspension, termination and signatures
Significant non-compliance permits immediate suspension by written notice. Examples include safeguard failures, late or inadequate information and institution/account classifications that frustrate CRS. Termination takes effect on the first day of the month after twelve months from notice, while previously received information remains protected by the DTA. The English agreement was signed in Singapore and Helsinki by Chia-Tern Huey Min for Singapore and Tarja Rautio for Finland.
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 ↗