IRAS has added Antigua and Barbuda to the jurisdictions with which Country-by-Country (CbC) Reports can be automatically exchanged, effective from financial year 2025.
Singapore’s Inland Revenue Authority of Singapore (IRAS) has expanded the list of jurisdictions with which it can automatically exchange CbC Reports to include Antigua and Barbuda. The authority updated its Country-by-Country Reporting guidance page on 8 October 2026. The addition takes effect from the financial year 2025.
International exchange
Under the guidance, information is exchanged automatically only with bilateral partner jurisdictions that meet Singapore’s standards on confidentiality, data protection and reciprocity. Singapore signed the Multilateral Competent Authority Agreement on 21 June 2017 and exchanges reports with the United States under a Bilateral Competent Authority Agreement.
Purpose of CbC Reporting
CbC Reporting was introduced under the OECD Base Erosion and Profit Shifting Action 13 Report. It requires Singapore-headquartered Multinational Enterprise groups to report their global allocation of income, taxes paid and key business activities. IRAS and foreign tax authorities use the reports to assess high-level transfer pricing risks and other Base Erosion and Profit Shifting-related risks.
Filing criteria
An entity must file a CbC Report with IRAS if it is the Ultimate Parent Entity of a Singapore Multinational Enterprise group and is a tax resident in Singapore. The group must also have total consolidated revenue of at least SGD 1,125 million in the preceding financial year and have subsidiaries or operating locations in at least one foreign jurisdiction.
Deadlines and notification
Reports must be submitted within 12 months from the end of the Ultimate Parent Entity’s financial year. For financial years beginning on or after 1 January 2022, Reporting Entities must notify IRAS of their filing obligation within three months of the financial year end, through FormSG. IRAS confirms filing obligations within two months of receiving the notification.
Submission format
Reports must follow the OECD CbCR XML Schema v2.0. The XML file must be compressed into a password-protected .zip file named after the Reporting Entity and emailed to IRAS. The password must be sent separately through FormSG and must be at least 12 characters long, with uppercase and lowercase letters, numbers and symbols.
Penalties for non-compliance
Non-compliance carries statutory penalties. Failure to notify, or late or non-filing, can result in a fine of up to SGD 5,000, plus a continuing daily fine of up to SGD 100. Failure to retain documents for five years can result in a fine of up to SGD 1,000, plus a continuing daily fine of up to SGD 50. Providing false or misleading information can result in a fine of up to SGD 10,000, imprisonment of up to two years, or both.
The update means Singapore-headquartered groups should note that their CbC Reports for financial year 2025 may now be shared with the tax authority of Antigua and Barbuda.
