Agreement, dates and legal basis
This seven-page Singapore–UK agreement was concluded 16 September 2016, entered into force and became effective 31 January 2017. Its legal basis is Article 27 of the 12 February 1997 bilateral Double Taxation Agreement, as amended by two protocols, rather than Article 6 of the multilateral Convention. It establishes reciprocal CRS exchange without prejudice to national legislative procedures; the source dates do not establish absence of later changes.
Section 1: territory and competent authorities
United Kingdom covers Great Britain/Northern Ireland, territorial sea and areas beyond with internationally consistent sovereign rights/jurisdiction. Its TINs are unique/personal identifiers; CRS is expressly defined and enacted updates anticipated.
Singapore’s authority is the Finance Minister or authorised representative; United Kingdom uses HMRC Commissioners or authorised representative (the original says Her Majesty’s). Singapore TIN is its tax reference number; the counterpart TIN is National Insurance Number or Unique Taxpayer Reference.
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. Place of birth is additionally specified in the case of the United Kingdom. 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. Double Taxation Agreement 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.
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 of mutual notifications confirming necessary CRS laws and pre-existing/new-account/due-diligence dates, transmission/encryption, supplying-country personal-data safeguards, adequate confidentiality with completed questionnaire, and ability to comply with the other side’s safeguards. Notify subsequent changes promptly.
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 United Kingdom by Aidan Reilly.
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 ↗