• Marco Zawar MBA/LLM (Tax)

Singapore - Why certain Singapore based FI´s might consider to outsource their FATCA reporting?

Updated: Apr 24

From 1 April 2020 onwards, all Reporting Singapore-based Financial Institutions (“SGFIs”) must submit their FATCA returns - including nil returns - electronically via the “Submit CRS or FATCA Return” e-Service at IRAS’ myTax Portal.

- IRAS does not accept FATCA returns filled in paper form from 2020 onwards -


Impact on certain SGFIs

SGFIs not having IT systems in place allowing them to file the FATCA relevant data based on the prevailing FATCA XML Schema are obliged, to file their FATCA relevant information with the “FATCA return via Fillable PDF” Form.

The Singapore Inland Revenue Authority (“IRAS”) on their Foreign Account Tax Compliance Act (FATCA) web-site announced, that an updated version of the “FATCA return via Fillable PDF” Form will be available on 6 May 2020 instead of 29 April 2020.

IRAS strongly encourages SGFIs filing their FATCA return via the "PDF Fillable Form" to use the updated version.

SGFIs deciding to use the fillable PDF form should consider that the form is limited to a maximum of 40 account reports or up to a maximum file size of 5MB.

IRAS endorse SGFIs to seek support from 3rd parties on FATCA return filing

IRAS supports SGFIs not having adequate resources available to seek services from 3rd party vendors supporting their FATCA return based on the prevailing FATCA XML Schema ensure to meet the reporting deadline 31 May 2020 and to stay FATCA compliant. IRAS stated that "Enforcement actions will be taken against Reporting SGFIs that do not submit their FATCA returns on time or do not submit their FATCA returns".

SGFIs currently in the process to evaluate a possibility to outsource their FATCA and/or CRS reporting instead using a PDF fillable form are invited to contact me and to find out how we can support your reporting needs for 2020 and the upcoming years 

About the Author

Marco is a certified Banker and holds degrees as MBA (finance and accounting) and LLM (international business and tax law).

Marco provides 30+ years of working experiences as internal auditor, business consultant, and project manager achieved within Commercial Banking Institutions, Private Banking Institutions, Wealth Management Organisations and Financial Service Provider located in Europe and the APAC Region.

Marco provided advisory services on

  • international tax transparency initiatives - AEoI, FATCA, EU-DAC6, OECD-CRS - to meet financial institutions AML/KYC, Customer due diligence, tax reporting and disclosure obligations;

  • the implementation of U.S Qualified intermediary regime (QI) and U.S 1099 tax reporting requirements;

  • the institution of investment compliance frameworks and policies supporting the monitoring of regulatory, contractual and bank internal investment restriction;


©2019 by Marco Zawar