Singapore–Norway CRS Agreement: Complete Exchange Rules

Agreement, dates and legal basis

This seven-page Singapore–Norway competent-authority agreement was concluded 25 October 2016, entered into force and became effective 31 January 2017. It provides reciprocal automatic CRS account-information exchange under the Convention on Mutual Administrative Assistance in Tax Matters. These are the original agreement dates, not proof that no later changes occurred.

Section 1: territory and competent authorities

Norway includes internationally consistent offshore seabed/subsoil/resource rights, but excludes Svalbard, Jan Mayen and Norwegian dependencies. The preamble recognises domestically enacted future CRS updates.

Singapore’s authority is the Finance Minister or authorised representative; Norway uses Finance Minister or authorised representative. Singapore TIN is its tax reference number; the counterpart TIN is personal identification number or organisation number.

Section 1: institutions, accounts and persons

Each jurisdiction’s financial institutions include domestic-resident institutions excluding foreign branches, and domestic branches of foreign institutions. Reporting institutions exclude non-reporting institutions. A reportable account is identified by CRS due diligence: an institution in one jurisdiction holds an account for reportable tax residents of the other, or a passive NFE with such controlling persons. Persons include resident individuals/entities and deceased residents’ estates. Undefined capitalised terms follow domestic law consistently with CRS; otherwise tax-law meaning prevails, subject to context or agreed meaning.

Section 2: identity and account information

Exchange account-holder name, address, TINs and birth date; for relevant entity accounts also entity and controlling-person identity. The identity list includes birth date, without a separate place-of-birth requirement in this agreement. Include account number or equivalent, institution name/identifying number and year-end balance/value, including insurance cash/surrender value; report closure if closed during the period.

Section 2: every income category

Custodial accounts: gross interest, dividends and other asset income, plus gross sale/redemption proceeds where the institution acts as custodian/broker/nominee/agent. Depository accounts: gross interest. Other accounts: gross paid/credited amounts where the institution is obligor/debtor, including aggregate redemptions. Proceeds and balance are not the same as taxable profit.

Section 3: years, currency and transmission

Payment character/amount follows the exchanging jurisdiction’s tax principles and identifies currency. Exchange for 2017 onwards within NINE MONTHS after calendar-year end, provided BOTH jurisdictions have matching reporting/due-diligence laws for the year. Singapore’s 2017 exchange excludes custodial gross sale/redemption proceeds; those begin with 2018 onwards. Authorities use CRS XML and agree transmission/encryption methods. Nine months is the inter-authority deadline, not automatically the institution’s domestic filing deadline.

Sections 4 and 5: errors and confidentiality

Notify counterpart of suspected inaccurate/incomplete reporting or institution non-compliance; the recipient authority uses appropriate domestic-law measures. Convention confidentiality/use limits and supplying-jurisdiction safeguards protect data. Notify immediately of a confidentiality breach or failed safeguards, including sanctions and remedial action. This does not make personal account records publicly available.

Norway’s section 5 also prohibits use or disclosure in proceedings contrary to the supplying jurisdiction’s public policy (ordre public).

Section 6: consultations and amendments

Either authority may seek consultation on interpretation/implementation. Amendments require written agreement; unless otherwise agreed, effective date is first day of the month after a one-month period from later signature or later exchanged notification. Do not replace this formula with an assumed immediate amendment date.

Section 7: effectiveness and notifications

Effectiveness is the later notification that necessary implementing laws are in place. This version uses the short notification provision, rather than a five-item checklist.

Section 7: suspension and termination

Written notice of significant non-compliance can suspend exchange IMMEDIATELY, including confidentiality failure, late/inadequate data or classifications frustrating CRS. Either authority may terminate: first day of the month after TWELVE MONTHS from notice. Previously received data stays protected after termination. Signed for Singapore by Chia-Tern Huey Min and for Norway by Ingebjørg Brekka.