Inland Revenue Authority of Singapore released FATCA updates related to IRS Notice 2023-11

Article 2 of the Agreement between the Government of the United States of America and the Government of the Republic of Singapore to Improve International Tax Compliance and to Implement FATCA (“IGA”) provides that Singapore reporting Model 1 FFI’s are required to report the US TIN of each US person who is (1) an account holder or (2) a controlling person of certain non-US entity’s.

On March 15th, 2023, the Inland Revenue Authority of Singapore (IRAS) released under Section B8 of their "IRAS FAQs on the Foreign Account Tax Compliance Act (FATCA)" and Paragraphs 7.6 and 7.7 of their "IRAS Supplementary XML Schema User Guide for Preparing the FATCA Reporting Data File" updates following the publication of IRS Notice 2023-11.

Notice 2023-11, released on December 30th, 2022, “provides temporary relief procedures for certain foreign financial institutions (FFIs) required to report U.S. taxpayer identification numbers (U.S. TINs) for certain pre-existing accounts as defined in an applicable Model 1 intergovernmental agreement (IGA).”

Take away

The reliefs provided in Notice 2023-11 are limited to pre-existing accounts and do not apply to U.S. reportable accounts opened after the enforcement date specified in the applicable Model 1 IGA (new accounts), including new accounts held by account holders of pre-existing accounts.

As per the requirements stipulated in Notice 2023-11 Singapore Reporting Model 1 FFIs should review the relief provisions and start activities to adjust existing due diligence and FATCA tax reporting procedures to stay compliant.