Exchange-of-Information Requests: Eighth-Schedule Requirements

Key steps and distinctions

A request must identify its purpose, the competent authority and the person concerned, and describe the information sought and the preferred form of response. It must state grounds for believing the information is held by the relevant Singapore tax authority or by someone in Singapore. The known name and address of a holder should be provided. The requesting authority must confirm conformity with its own law and administrative practice and its power to obtain that information domestically. It must also explain that available domestic means were pursued except those creating disproportionate difficulty. Requirements in the prescribed exchange arrangement and other helpful information complete the request. These requirements define a government-to-government tax-information request, not a private person’s right to demand another taxpayer’s records. Identify the person, relevance and evidence sought concretely; a broad label such as overseas account does not replace the statutory particulars. The extract references section 105D(2), so the governing arrangement and current statute should be read alongside it when preparing or assessing a request.