CRS XML Consultation: TINs, Identifiers and Account Reports

Key steps and distinctions

IRAS received 75 comments and accepted 53 before issuing the first guide on 13 October 2017. A reason for missing TIN became optional in the XML return, but institutions still had to obtain valid self-certifications, record reasons and demonstrate reasonable efforts when reviewed. Optional transmission did not eliminate underlying due diligence. The unique-reference part of DocRefID increased from 15 to 30 characters, and a file-preparation/submission section was added. Certain XML characters require escaping, while specified unsupported character sequences were prohibited. IRAS retained separate account reports for each passive-NFE controlling person and each tax-residence jurisdiction to route information correctly and simplify corrections. Multiple relationships of the same controlling person, such as settlor and beneficiary, could repeat the controlling-person element within that account report. MessageTypeIndic was confirmed mandatory, while City was not required when AddressFree was used. These responses explain the original schema design and Singapore-specific requirements. They are historical, not a replacement for the currently applicable schema version, validations or submission guide. Preserve self-certification evidence separately from the transmitted XML fields.