Singapore: Updated FATCA FAQs

The Inland Revenue Authority of Singapore (IRAS) on June 21, 2024, issued updated FATCA “frequently asked questions” (FAQs), revising question B.8 under the Identification and Reporting Obligation section.

The updated question reminds reporting Singapore financial institutions to adhere to the procedures outlined in sections 3.02, 3.03, and 3.04 of Internal Revenue Service (IRS) Notice 2023-11.

Per Notice 2023-11, Singapore financial institutions reporting for calendar year 2024 (due May 31, 2025) will not be considered significantly non-compliant if they are unable to report the required U.S. taxpayer identification number (TIN) for pre-existing U.S. accounts, provided certain conditions are met. Singapore financial institutions with a missing U.S. TIN are eligible for this relief if they:

• Obtain and report the date of birth of each individual account holder and Controlling Person whose U.S. TIN is not reported
• Annually request for any missing U.S. TIN from each account holder by proper methods of communication that are likely to reach each account holder, including either:
  • The web address of the State Department’s Joint FATCA FAQs
  • A copy of the FAQs and either a copy of the relief procedures published by the IRS for specific former citizens or the web address
• Annually search for any missing U.S. TIN in the electronically searchable data maintained by the reporting Model 1 FFI
• Use the accurate and updated U.S. TIN codes for each U.S. account holder whose U.S. TIN is missing

Also, per the notice, when requesting missing TINs, reporting Singapore financial institutions need to encourage U.S. citizens/residents to provide their U.S. TIN but must not discriminate against those who do not provide it.

Read a June 2024 report prepared by the KPMG member firm in Singapore