From Start to Finish

Your CRS solution from start to finish for private equity, venture capital, and other investment funds;  fund administrators  and  trustees. Preparation of CRS and FATCA xmls, tailored to your funds, documentation of account holder CRS and FATCA status and electronic submission of CRS and FATCA Returns.

Latest update – common reporting standard

Increased Penalties for CRS Regulation and Filing Offences

In the December 2021 update, IRAS (Inland Revenue Authority of Singapore) announced that with effect from 16 November 2021, the penalties for CRS non-regulation and non-filing offences have been increased to $5,000 upon conviction, and a further fine of $100 per day for a continuing offence.

IRAS notes that over 90% of Reporting SGFIs (Reporting Singapore Financial Institutions) have filed their annual CRS returns on time.

The IRAS CRS Compliance Guide sets-out a compliance framework for Reporting SGFIs to put in place the necessary controls to ensure compliance with CRS reporting obligations, including CRS policies, procedures and controls to ensure accurate, complete and timely CRS reporting.

The CRS Compliance Guidelines e-Tax Guide describes a compliance framework that assists Reporting SGFIs to develop policies, procedures and controls to demonstrate the sufficiency and robustness of your operating environment, to fulfil its CRS due diligence obligations and CRS reporting obligations.

Please refer to the CRS Compliance section for more information.

Previous Up-dates

On 1 February 2021 IRAS published a reminder that CRS XML Schema Version 2.0 has come into effect from 1 February 2021. All new, nil, corrected or deletion CRS returns in XML format, including returns relating to Reporting Years 2017 to 2019, must be formatted and submitted using the CRS XML schema Version 2.0 with effect from 1 February 2021.

IRAS also published a reminder that CRS registration deadline for an entity that became a Reporting SGFI between 1 January 2020 and 31 December 2020 (both dates inclusive) is 31 March 2021.

Regulation 10(1) of Singapore’s Income Tax (International Tax Compliance Agreements) (United States of America) Regulations 2015 requires that a reporting Singaporean financial institution must, in respect of 2014 and every following calendar year, prepare and provide to Comptroller, or a person authorised by the comptroller under section 105L of the Income Tax Act.

Regulation 10 (4) clarifies that if, during the calendar year in question, the reporting Singaporean financial institution maintains no U.S. reportable accounts, the return must state that fact.

On 23 July 2019 the IRAS published the CRS Compliance Guideline e-Tax Guide.

It is a useful document which sets-out the frame work so that RFI (reporting financial institutions) and Trustees of trusts that are RFIs maybe able to demonstrate CRS compliance.

Paragraph 4.4 of the Guide states that: “IRAS will conduct reviews on Reporting SGFIs for their compliance with CRS. IRAS’ reviews will be guided by the following key elements:

  • IRAS’ expectations of Reporting SGFIs’ CRS compliance approach;
  • CRS internal controls, specifically a set of 23 hallmarks or desired outcomes that are aligned with Reporting SGFIs’ CRS obligations and would demonstrate their effective compliance with CRS;
  • A self-review toolkit that Reporting SGFIs may use to assess the sufficiency and robustness of their CRS internal controls;

In paragraph 5.1.3 IRAS states that it “will take the right actions at the right time.

  • IRAS will work with and assist Reporting SGFIs that are voluntarily compliant to ensure their compliance with CRS in Singapore.
  • On the other hand, IRAS will not hesitate to take deterrent measures such as issuing warnings and imposing penalties on errant Reporting SGFIs that choose to be non-compliant.

For a presentation on the CRS Compliance Guideline e-Tax Guide the above , please contact us.

Crs Services & Solutions you can trust !

Our CRS solutions are tailored to the needs of venture capital, private equity and other funds, and trustees.

How Can we help?

Your Issues


  • Your senior stakeholders require assistance of an experienced CRS expert with funds/trust experience
  • Demonstrating that CRS regulatory up-dates are considered, impact assessment conducted, and conclusions documented
  • Developing a CRS compliance approach – including policies, procedures and processes
  • Documenting a Compliance Framework that meets the CRS Compliance Tool-kit provided by the IRAS

CRS Solutions for Private Equity

  • Our resources specialise in CRS and FATCA
  • Areas of expertise include private equity, venture capital, and investment structures including trustee documented trusts
  • Our processes are designed and optimised for each client’s industry and business needs

Engage Solution Provider

  • Cost effective access to a resource with over 30 years of international tax expertise and 5 years of CRS experience
  • Your team is freed-up to focus on their  respective areas of expertise
  • Your time is better spent generating value for your investors and your high net worth clients

How Can we help?

Your Issues

Our Experience 

A team with over 30 years of international tax experience, specialised private equity expertise and 5 years of CRS experience.


Our expertise is in designing CRS processes that solve the CRS needs of fund managers, general partners and fund entities that are financial insitutions*. We specialise in solutions for private equity funds.

* a defined term under CRS regulations


Our disciplined focus on funds creates efficient, dependable and cost effective solution development processes in this area that is both complex and specialised.

How Can we help?

What is CRS

CRS is the Common Reporting Standard for reporting of private equity investor information* to the tax authorities of their country of tax residence**. 

– a term defined by CRS Regulations and interpreted in the context of agreements that establish partnerships, trusts and/or entities in the private equity funds context

–  a term defined by common law and CRS Regulations. Read more…

How is CRS given effect in Singapore? 

The international CRS framework requires signatory countries to pass local rules aligned with the common standard. Read more…

What are the CRS guidance that interpret the regulations? 

The CRS framework and its Regulations are interpreted in general terms and also in the context of industries and transactions. See for example:

CRS Solutions Asia

What Else To Monitor ?

Signatory countries sign-up to multi-lateral and bi-lateral agreements to give effect to the reporting of information to each other. The interpretation of each agreement can be different and has to be understood in the context of the framework. Read more…