Operationalising CARF and CRS 2.0: From Policy to Practical Implementation

A group photo of attendees along with the speakers of the Operationalising CARF and CRS 2.0: From Policy to Practical Implementation programme.

From Global Developments to Practical Implementation

Tax Academy of Singapore’s Operationalising CARF and CRS 2.0: From Policy to Practical Implementation session brought together perspectives from banking, digital assets, professional services, industry, technology and government.

The discussion reflected a key theme throughout the session: as CARF and the amended Common Reporting Standard evolve, organisations will need to consider not only the tax requirements, but also how these requirements interact with their broader data, systems, governance and compliance processes.

The session followed the implementation journey from the international landscape, to Singapore’s implementation roadmap, and finally to the practical realities organisations may need to work through as implementation approaches.

Understanding the Global Landscape

Dr. Max Bernt of Taxbit opened the session with an overview of OECD developments and the evolving implications of CARF, including issues relating to tokenisation and stablecoins.

A key consideration emerging from the discussion was the changing nature of information reporting.

Traditional information-reporting regimes have largely centred on financial accounts and account holders. CARF introduces a greater focus on transaction-level information relating to crypto-assets, requiring organisations to consider how transactions are classified, linked to customer and tax information, and supported by appropriate records.

For organisations managing significant volumes of digital asset transactions, this can create a different data and systems challenge from those associated with existing reporting frameworks.

Dr. Max Bernt of Taxbit talking about the Global Landscape

Singapore’s Implementation Roadmap

Lim Zhi Wei and Pang Cheng Jong from the Inland Revenue Authority of Singapore (IRAS) shared the latest developments relating to Singapore’s CARF rollout and amendments to the CRS, including implementation considerations, compliance expectations and support.

The discussion, moderated by Mercy Joseph of Alvarez & Marsal, provided participants with an opportunity to consider how policy developments may translate into organisational preparation.

As Pang Cheng Jong subsequently reflected, successful implementation goes beyond tax policy. Organisations may also need to consider their data, systems, governance and compliance processes as they prepare for the new frameworks.

Q&A Session on IRAS' Perspective and Singapore Updates

Navigating the Interaction Between CARF and CRS

The session also explored how CARF and the amended CRS may interact as financial products continue to evolve.

Among the issues discussed was the boundary between Specified Electronic Money Products under the CRS and crypto-assets under CARF, particularly in relation to stablecoins.

As traditional finance, digital assets and tokenised products increasingly intersect, understanding how particular products fall within the respective frameworks becomes an important part of implementation planning.

Participants also discussed practical due diligence considerations, including circumstances that may give rise to additional enquiries in higher-risk cases.

From Policy to the Realities of Implementation

The final industry roundtable brought together Wesley Kow of UOB, Sima Shah of EY Singapore, Derek Koh of OKX and Peter Brewin of PwC Hong Kong, and was moderated by Dr. Max Bernt.

The discussion focused on what organisations may need to work through as implementation approaches.

Practical considerations included transaction data, customer information, product classification, systems capabilities and supporting audit trails.

The exchange also considered how existing FATCA and CRS infrastructure may need to adapt to the scale and nature of transaction-level reporting under CARF.

For financial institutions, this may involve considering how existing reporting infrastructure needs to evolve. For digital asset businesses, it may involve managing transaction-level reporting across significant volumes of activity.

Roundtable Discussion

Key Takeaways

Several themes emerged from the session:

• Implementation extends beyond tax policy. Preparing for CARF and CRS 2.0 also raises considerations around data, systems, governance and compliance processes.

• CARF brings a different data challenge. Transaction-based reporting requires organisations to understand transaction flows, classify transactions and connect them with relevant customer and tax information.

• The interaction between CARF and CRS is an important implementation consideration. Discussions included the boundary between Specified Electronic Money Products under CRS and crypto-assets under CARF, including in relation to stablecoins.

• Information-reporting systems are an important part of readiness. The discussion highlighted how existing reporting infrastructure may need to respond to transaction-level reporting and larger volumes of data.

• Continued dialogue between regulators and industry is valuable. Bringing together government, financial institutions, digital asset businesses, advisers and technology specialists allowed implementation issues to be considered from different perspectives.

Bringing Different Perspectives Together

One of the distinguishing features of the session was the diversity of perspectives represented in the room.

Regulators, advisers, financial institutions, digital asset businesses, technology specialists and other industry participants were able to exchange views on both the policy direction and the practical challenges of implementation.

Tax Academy of Singapore thanks Dr. Max Bernt, Zhi Wei Lim, Cheng Jong Pang, Mercy Joseph, Wesley Kow, Sima Shah, Derek Koh and Peter Brewin, together with all participants, for contributing to a highly interactive and practical exchange.

By bringing together perspectives from across the tax transparency ecosystem, the session supported continued dialogue as emerging international tax developments move from policy towards implementation.

Speakers of the Operationalising CARF and CRS 2.0 programme

Explore the Programme

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