Global Tax Alert | 28 June 2013
Singapore announces changes to corporate income tax objection and appeal process
Effective 1 January 2014, the Inland Revenue Authority of Singapore (IRAS) will implement certain administrative changes to the corporate income tax objection and appeal process, primarily to expedite the closure of tax issues and achieve tax certainty.
The revised objection and appeal process will apply to the following taxpayers:
- • Companies
- • Registered business trusts
- • Real estate investment trusts
- • Permanent establishments in Singapore, including Singapore branches of foreign companies
It will cover all assessments raised by the Comptroller of Income Tax (CIT), except for assessments based on estimated taxable income furnished by the taxpayer.
Stages in the objection and appeal process:
The objection and appeal process consists of four stages:
- • Objection to a Notice of Assessment issued by CIT
- • Review of the objection and information by CIT
- • Litigation, if taxpayer disagrees with CIT’s decision
- • Finalization of the assessment
The revised administrative procedures mainly relate to those at the objection and review stages.
Prior to 1 January 2014
From 1 January 20141
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When a Notice of Refusal to Amend is issued, the taxpayer will have to either accept the CIT’s decision, in which case the assessment will be regarded as final and conclusive, or file a Notice of Appeal to the Income Tax Board of Review within 30 days from the date of the Notice of Refusal to Amend if it does not agree with the CIT’s decision.
The changes made by the IRAS are intended to streamline the objection and appeal process and expedite the closure of taxpayers’ income tax matters. The milestones set at each stage of the process are guidelines given to both CIT and taxpayers; however, it is expected that the CIT will continue to exercise flexibility in granting extension of time in genuine circumstances.
1. The changes will apply to Notices of Assessment issued on or after 1 January 2014.
2. Acknowledgement of the validity of the objection is based on the declaration in the Objection Form or IRAS’ e-Services.
3. The CIT generally expects a reply from the taxpayer within two months from the date of the CIT’s letter, and will send reminders if no reply is received after the deadline. A final reminder will be sent to the taxpayer, highlighting the consequences of not furnishing a reply to the CIT’s queries, before the issue of a Notice of Refusal to Amend.
For additional information with respect to this Alert, please contact the following:
Ernst & Young Solutions LLP, Singapore
- • Adrian Ball
+65 6309 8787
- • Russell Aubrey
+65 6309 8690
- • Chung-Sim Siew Moon
+65 6309 8807
- • Lim Joo Hiang
+65 6309 8654
Ernst & Young LLP, Asia Pacific Business Group, New York
- • Chris Finnerty
+1 212 773 7479
- • Jeff Hongo
+1 212 773 6143
- • Kaz Parsch
+1 212 773 7201
- • Bee-Khun Yap
+1 212 773 1816
EYG no. CM3573