§ 105K — International tax compliance agreements

105K.—(1) The Minister may by order declare any of the following as an international tax compliance agreement for the purposes of this Part:(a)

the agreement reached between the Government and the Government of the United States of America to facilitate compliance by financial institutions and other persons in Singapore with the Foreign Account Tax Compliance Act of the United States of America (FATCA);

(aa)

a competent authority agreement between —(i)

the Government and —(A)

the government of another country; or

(B)

the governments of 2 or more countries; or

(ii)

the Minister or the Minister’s authorised representative and —(A)

the authority of another country that exercises a power or carries out a duty corresponding to a power or duty of the Minister or representative; or

(B)

the authorities of 2 or more countries that exercise powers or carry out duties corresponding to a power or duty of the Minister or representative;

(ab)

a CbCR exchange agreement between —(i)

the Government and —(A)

the government of another country; or

(B)

the governments of 2 or more countries; or

(ii)

the Minister or the Minister’s authorised representative and —(A)

the authority of another country that exercises a power or carries out a duty corresponding to a power or duty of the Minister or representative; or

(B)

the authorities of 2 or more countries that exercise powers or carry out duties corresponding to a power or duty of the Minister or representative;

(ac)

a CARF agreement between —(i)

the Government and —(A)

the government of another country; or

(B)

the governments of 2 or more countries; or

(ii)

the Minister or the Minister’s authorised representative and —(A)

the authority of another country that exercises a power or carries out a duty corresponding to a power or duty of the Minister or representative; or

(B)

the authorities of 2 or more countries that exercise powers or carry out duties corresponding to a power or duty of the Minister or representative;[Act 25 of 2025 wef 08/12/2025]

(b)

any agreement modifying or supplementing an agreement in paragraph (a), (aa), (ab) or (ac);[Act 25 of 2025 wef 08/12/2025]

(c)

any other agreement or arrangement that makes provision corresponding, or substantially similar, to that made by an agreement in paragraph (a), (aa), (ab), (ac) or (b), between —(i)

the Government and —(A)

the government of another country; or

(B)

the governments of 2 or more countries; or

(ii)

the Minister or the Minister’s authorised representative and —(A)

the authority of another country that exercises a power or carries out a duty corresponding to a power or duty of the Minister or representative; or

(B)

the authorities of 2 or more countries that exercise powers or carry out duties corresponding to a power or duty of the Minister or representative.[15/2016; 34/2016; 39/2017]

[Act 25 of 2025 wef 08/12/2025]

(2) An order under subsection (1) may only take effect on or after the date on which the agreement or arrangement enters into force for Singapore or, where there is more than one agreement or arrangement under the order, may only take effect in relation to each agreement or arrangement on or after the date on which that agreement or arrangement enters into force for Singapore.[39/2017]

—(1) The Minister may by order declare any of the following as an international tax compliance agreement for the purposes of this Part:(a)

the agreement reached between the Government and the Government of the United States of America to facilitate compliance by financial institutions and other persons in Singapore with the Foreign Account Tax Compliance Act of the United States of America (FATCA);

(aa)

a competent authority agreement between —(i)

the Government and —(A)

the government of another country; or

(B)

the governments of 2 or more countries; or

(ii)

the Minister or the Minister’s authorised representative and —(A)

the authority of another country that exercises a power or carries out a duty corresponding to a power or duty of the Minister or representative; or

(B)

the authorities of 2 or more countries that exercise powers or carry out duties corresponding to a power or duty of the Minister or representative;

(ab)

a CbCR exchange agreement between —(i)

the Government and —(A)

the government of another country; or

(B)

the governments of 2 or more countries; or

(ii)

the Minister or the Minister’s authorised representative and —(A)

the authority of another country that exercises a power or carries out a duty corresponding to a power or duty of the Minister or representative; or

(B)

the authorities of 2 or more countries that exercise powers or carry out duties corresponding to a power or duty of the Minister or representative;

(ac)

a CARF agreement between —(i)

the Government and —(A)

the government of another country; or

(B)

the governments of 2 or more countries; or

(ii)

the Minister or the Minister’s authorised representative and —(A)

the authority of another country that exercises a power or carries out a duty corresponding to a power or duty of the Minister or representative; or

(B)

the authorities of 2 or more countries that exercise powers or carry out duties corresponding to a power or duty of the Minister or representative;[Act 25 of 2025 wef 08/12/2025]

(b)

any agreement modifying or supplementing an agreement in paragraph (a), (aa), (ab) or (ac);[Act 25 of 2025 wef 08/12/2025]

(c)

any other agreement or arrangement that makes provision corresponding, or substantially similar, to that made by an agreement in paragraph (a), (aa), (ab), (ac) or (b), between —(i)

the Government and —(A)

the government of another country; or

(B)

the governments of 2 or more countries; or

(ii)

the Minister or the Minister’s authorised representative and —(A)

the authority of another country that exercises a power or carries out a duty corresponding to a power or duty of the Minister or representative; or

(B)

the authorities of 2 or more countries that exercise powers or carry out duties corresponding to a power or duty of the Minister or representative.[15/2016; 34/2016; 39/2017]

[Act 25 of 2025 wef 08/12/2025]

(2) An order under subsection (1) may only take effect on or after the date on which the agreement or arrangement enters into force for Singapore or, where there is more than one agreement or arrangement under the order, may only take effect in relation to each agreement or arrangement on or after the date on which that agreement or arrangement enters into force for Singapore.[39/2017]