If your business is part of a large multinational group, there is a reporting obligation that sits above ordinary corporate tax filing and often catches Singapore finance teams by surprise: Country-by-Country Reporting (CbCR). It requires the biggest multinational enterprise (MNE) groups to give tax authorities a jurisdiction-by-jurisdiction picture of where they earn revenue, book profit, pay tax, employ people and hold assets. Singapore adopted CbCR as part of the OECD’s BEPS project, and IRAS administers it here.
This 2026 guide explains who has to file a CbC Report in Singapore, what the report must contain, when it is due, how it is exchanged with other countries, and how it fits alongside your transfer pricing documentation and global minimum tax (Pillar Two) obligations. If your group is near the threshold, the time to get organised is before, not after, the deadline.
What is Country-by-Country Reporting?
CbCR is a standardised annual report, developed under Action 13 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) project, that large MNE groups submit to their home tax authority. The report is then automatically exchanged with the tax authorities of other jurisdictions where the group operates, under an international exchange framework.
The purpose is transparency. Tax authorities use CbC Reports as a high-level risk-assessment tool, to see whether a group’s profits are aligned with where its real economic activity, people and assets sit. It is not itself a basis for a tax assessment, but a mismatch between profit and substance in a jurisdiction can prompt closer scrutiny, including a transfer pricing review.
Which groups must file in Singapore?
The Singapore CbCR obligation applies to a Singapore-headquartered MNE group where the ultimate parent entity is tax resident in Singapore, the group has subsidiaries or operations in at least one foreign jurisdiction, and the group’s consolidated group revenue in the preceding financial year was at least S$1.125 billion.
The S$1.125 billion threshold is Singapore’s equivalent of the OECD’s EUR 750 million benchmark. If your ultimate parent is not in Singapore, your Singapore entity usually does not have to file the CbC Report itself, because that duty falls on the parent in its home country. Singapore instead receives the report through automatic exchange. Local filing by a Singapore subsidiary is only triggered in narrow fallback situations, for example where the parent’s jurisdiction has no exchange relationship with Singapore.
Quick eligibility check
| Question | Filing in Singapore? |
|---|---|
| Ultimate parent is Singapore tax resident and group revenue ≥ S$1.125b | Yes, file CbC Report with IRAS |
| Ultimate parent is overseas, group files CbCR there | Generally no local filing; IRAS receives it by exchange |
| Group revenue below S$1.125b | No CbC Report required |
What the CbC Report must contain
The report is built around a fixed template. For each tax jurisdiction in which the group operates, it must set out aggregate figures and a list of the entities based there.
Data reported per jurisdiction
| Field | What it captures |
|---|---|
| Revenue | Split between related-party and unrelated-party revenue, plus total |
| Profit (loss) before income tax | Aggregate for the jurisdiction |
| Income tax paid (cash basis) | Tax actually paid during the year |
| Income tax accrued (current year) | Tax expense for the year |
| Stated capital and accumulated earnings | Aggregate capital position |
| Number of employees | Headcount in the jurisdiction |
| Tangible assets (other than cash) | Net book value of physical assets |
| List of constituent entities and activities | Each entity, its jurisdiction of residence and main business activity |
Deadline and how to file
A Singapore ultimate parent must file its CbC Report with IRAS within 12 months from the end of the group’s financial year. So for a group with a 31 December 2025 year end, the CbC Report for that year is due by 31 December 2026. The report is filed electronically with IRAS in the prescribed XML schema.
Because the report draws on consolidated figures across every jurisdiction, gathering and reconciling the data takes time. Groups that leave it to the last month often struggle to reconcile the CbCR numbers with their statutory accounts and their corporate tax positions. Start the data collection early in the year.
Exchange, confidentiality and appropriate use
Once filed, IRAS exchanges the CbC Report with the tax authorities of jurisdictions where the group operates and which have an exchange relationship with Singapore. In return, IRAS receives reports on foreign-parented groups with a Singapore presence. The information is confidential and is subject to “appropriate use” safeguards, meaning it should be used for high-level transfer pricing and BEPS-related risk assessment, not as a direct basis for a tax adjustment. This exchange framework is conceptually similar to the automatic exchange under the Common Reporting Standard (CRS), though CbCR concerns corporate group data rather than financial account information.
How CbCR fits with your other tax obligations
CbCR sits at the top of a three-layer transfer pricing framework: the CbC Report (group-wide overview), the master file (group’s global business and TP policy) and the local file (the Singapore entity’s related-party transactions). Larger MNE groups typically prepare all three. Increasingly, groups near the CbCR threshold also fall within the global minimum tax (Pillar Two) regime, which uses similar consolidated-revenue tests. Keeping these datasets consistent with each other, and with your statutory accounts, is what reduces audit risk.
Penalties
Failing to file the CbC Report, filing late, or providing incorrect information are offences under the Income Tax Act. It is therefore important to identify early whether your group is a reporting group, and to keep the underlying data clean throughout the year rather than reconstructing it under time pressure.
Frequently asked questions
Our parent is overseas. Do we file anything in Singapore?
Usually not. Where the overseas parent files a CbC Report in its home jurisdiction and that jurisdiction exchanges with Singapore, your Singapore entity has no local filing obligation. Local filing is a fallback that applies only in limited circumstances, such as the absence of an exchange relationship.
Is CbCR the same as transfer pricing documentation?
No, but they are related. CbCR is a high-level, group-wide overview. Transfer pricing documentation (master and local file) is the detailed, transaction-level support for your pricing of related-party dealings. Most groups that file CbCR also need robust TP documentation.
Does CbCR create a tax liability?
Not directly. It is a risk-assessment and transparency tool. However, if it reveals profit that is out of step with substance in a jurisdiction, it can trigger a transfer pricing enquiry that leads to an adjustment.
If your group is approaching the S$1.125 billion mark, Raffles Corporate Services can help you assess whether you are a reporting group and coordinate CbCR with your transfer pricing and tax compliance. Reach us through our contact page.
You can read IRAS’s guidance at iras.gov.sg and the Income Tax Act on Singapore Statutes Online.
— The Editorial Team, Raffles Corporate Services