Consultation and historical first filing
The consultation ran from 12 June to 12 July 2017, receiving 75 comments and accepting 53. The final first edition appeared 13 October 2017; first CRS XML returns were due 31 May 2018. The draft followed OECD CRS XML v1.0, while some feedback compared the OECD user guide v2.0. These are historic schema versions and deadlines, not a current submission specification.
1: missing TIN reasons became optional in XML
IRAS accepted the request with modification. New-account self-certification still needs tax residence and TIN; where unavailable, the reason is captured in certification. Reporting that reason in XML became optional to avoid extra system-transfer costs, but compliance reviews still require a reasonable explanation and evidence of reasonable efforts to obtain TIN. Optional transmission does not mean optional due diligence.
2 and 3: references and preparation
The unique-reference component of DocRefID grew from a maximum 15 to 30 characters, alongside reporting year and SGFI tax-reference number. IRAS added Part B on XML preparation/submission to address naming conventions and size questions. This response document announces guidance, but supplies no actual file-size limit to copy into a present-day article.
4: character handling
The table maps ampersand, apostrophe, less-than, greater-than and double-quote characters to their XML entities, respectively &, ', <, > and ". It gives no acceptable equivalent for hash (#), double dash (--) or slash-asterisk (/*). This is the document’s data-content guidance; it does not prohibit XML’s own structural angle brackets. Preserve proper escaping rather than remove all XML syntax.
5 and 6: persons, residences and relationships
IRAS rejected removing separate reports: a Passive NFE’s multiple controlling persons are separated into one report per person, and multiple tax residences into one report per jurisdiction, for correct routing and easier error correction. It accepted repeated controlling-person elements within the same account report for different relationships of ONE person, such as settlor and beneficiary. Multiple roles of one person are different from multiple people.
7 and 8: mandatory header and free address
MessageTypeIndic in the header is mandatory. City need not be provided when AddressFree is used. These responses clarify specific field requirements; they do not remove other schema requirements or establish that the old edition remains sufficient for current reporting.
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 ↗