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Singapore Adds To Guidance On ICAP Participation

Monday, March 21, 2022

The Inland Revenue Authority of Singapore (IRAS) has issued guidance for taxpayers on accessing the International Compliance Assurance Programme, a voluntary risk assessment and assurance program.

IRAS began participating in ICAP from 2021. Developed by the OECD, ICAP is intended to facilitate co-operative multilateral engagements between multinational enterprises (MNEs) and tax administrations, to enable the parties to agree on the international tax treatment that should apply to the taxpayer's affairs.

IRAS has said that an MNE's suitability for ICAP will be considered on a case-by-case basis. An MNE may indicate an interest in participating in ICAP to the tax administration in the jurisdiction of its ultimate parent entity (UPE). Alternatively, it may be approached by the tax administration in the jurisdiction of its UPE to discuss possible participation.

The tax agency has updated its guidance, including its FAQs, to explain how to participate in the ICAP. The updated guidance describes an option for an MNE group to indicate its preferences as to which tax administrations should participate in its ICAP risk assessment. IRAS said: "These preferences will be taken into account by the tax administrations in considering whether they will participate in the MNE group's ICAP risk assessment, but are not determinative."

The guidance further states: "The deadlines for submission of an application to participate in the ICAP can be found on the OECD's website. MNE groups that wish to discuss possible participation in the ICAP should contact the UPE tax administration in advance of the deadline."

The next deadlines for submission of an application to participate in ICAP are March 31, 2022, and September 30, 2022.