Detailed Guide: Procedure for Appealing Singapore Company Tax Notice from the Inland Revenue Authority of Singapore (IRAS)
Singapore 
Updated on January 06 
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content
- 1. Details of Singapore corporate tax appeal process
- 2. Common appeal cases and requirements for proof
- 3. Important notes when appealing Singapore corporate tax
- 4. How does GLA support businesses in tax appeals against Singapore companies?
- 5. Frequently asked questions about tax appeals with Singapore companies
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Upon receipt of a Notice of Assessment ("NOA") from the Internal Revenue Service of Singapore (IRAS), many businesses may disagree with the tax assessed due to factors such as miscalculation of revenue, no tax incentives, or deny valid deductionsIn these cases, the business has the right to file a tax protest for IRAS to review and adjust their tax liability.
So how is it that we so often forget to teach respect by respecting the children themselves? How does the tax appeal process work in Singapore?? How to file a valid application and increase the success rate? This article will guide you from A to Z, helping businesses meet IRAS requirements, avoid mistakes and protect maximum tax benefits.
1. Details of Singapore corporate tax appeal process
Main steps in procedure tax protest Singapore company:
- Objection Stage
- Review Stage
- Litigation Stage
- Finalisation Stage
1.1 Objection Stage
Target: Businesses can file an appeal if they disagree with a tax notice from the Inland Revenue Authority of Singapore (IRAS).
- Duration: 2 month from the date of receipt of NOA.
- How to apply:
- Via myTax Portal (recommended to use the "Revise/Object to Assessment" service).
- Submit the Objection Form by email or post.
- Send a letter/email stating the reason for the appeal.
- Requirement: Businesses need to provide the specific reasons for appeal, with valid supporting documents.
The appeal shall state the grounds for objection to be effective, including the following details:
- Year of review (YA).
- Describe the objectionable items.
- The amount of income/deduction for each disputed item; and
- Reasons why deductions/allowances/reductions/or non-taxable income should be allowed.
1.2 Review Stage
Target: IRAS considers the appeal and decides whether to adjust the tax amount.
IRAS will:
- Request additional documents (if necessary) and the business must respond in 2 month.
- Review and decide within 6 months since receiving full information.
- If additional time is required, IRAS will notify in advance.
Possible outcomes:
- IRAS agreed with the appeal and adjusted the tax amount.
- IRAS disagreed and upheld the assessed tax.
1.3 Litigation Stage
Target: If the Enterprise does not agree with the decision of IRAS, the Enterprise can file a lawsuit in court according to the provisions of law.
- IRAS will issue a "Notice of Refusal to Amend", if:
- The company disagrees with the final decision of IRAS.
- Incomplete appeal file within is 2 years from the date of receipt of the application by IRAS.
- Businesses have the right to complain to:
- Income Tax Board of Review (“ITBR”) within 30 tusksy since receiving "Notice of Refusal to Amend".
- If you disagree with the ITBR, you can continue to appeal to the High Court and the Court of Appeal.
1.4 Finalisation Stage
Target: Finalize the final decision on the tax obligations of the enterprise.
- Case of closing appeal:
- The company accepts the decision of IRAS.
- The enterprise did not submit an appeal within the prescribed time limit.
- The court has made a final judgment and the business no longer has the right to appeal.
2. Common appeal cases and requirements for proof
When a business receives a Notice of Assessment from the Singapore Revenue Authority (IRAS) but do not agree with the applied taxes, the Enterprise has the right to appeal. Below are some common appeal cases , and Documents to prepare to demonstrate the reasonableness of the tax adjustment request.
2.1 Are profits from the sale of assets taxable?
Problem: Businesses may object if they believe that profits from the sale of real estate or investment assets are capital gains and should not be taxed.
Documents to prepare:
- Property address or name of the company that owns the property.
- Purchase date, purchase price, financing source.
- Date of sale, price of sale, sales contract.
- Reason for buying and selling assets and proof that they are not for commercial purposes.
- Supporting documents such as market research reports, board resolutions.
2.2 Are legal fees tax deductible?
Problem: A business may object if IRAS refuses to deduct legal expenses that the business considers to be valid.
Documents to prepare:
- Details of legal services used.
- Invoices, legal service contracts.
- The reason to prove that this expense is for business purposes.
2.3 Are research & development (R&D) expenses eligible for tax exemption?
Problem: Businesses can object if IRAS does not accept R&D expenses under Article 14C/14D/37F of the Tax Act.
Documents to prepare:
- Describe the R&D project in detail, its objectives and benefits.
- Project start and end dates.
- List of expenses (salaries, equipment, materials, etc.).
- Contract or memorandum of understanding if the project is carried out by a third party.
2.4 Unreasonable Interest Adjustment
Problem: IRAS uses the Total Asset Method to determine interest, but businesses argue that this method is inaccurate.
Documents to prepare:
- List of assets not using borrowed capital.
- Proof of asset financing (bank statements, loan agreements).
- Tax and financial records demonstrate a more appropriate interest calculation.
2.5 Are head office expenses validly allocated?
Problem: The company may object if IRAS does not accept the allocation of expenses from the overseas head office to the Singapore branch.
Documents to prepare:
- How to calculate cost allocation.
- Confirm that the costs are only related to operations in Singapore.
- Service contract between head office and Singapore branch.
2.6 Other cases in which the enterprise may appeal
| Items | Problem | Documents to prepare |
| Capital Allowance | IRAS does not accept depreciation of assets under Article 19/19A. | Sales contract, invoice, proof of property used for business. |
| Office Repair Costs (R&R Deduction - Section 14N) | IRAS does not accept office repair costs. | Detailed list of repair items, invoices, construction contracts. |
| Foreign-Sourced Income | IRAS refuses to exempt foreign income from tax. | Proof of tax paid in home country, tax residency certificate, financial statements. |
| Bank Guarantee Fees | IRAS does not allow this expense to be deducted. | Guarantee contract, loan agreement, business reason for guarantee. |
| Facility Fees | IRAS considered this fee to be an ineligible expense. | Loan agreement, loan cost calculation sheet, and justification for this cost to reduce interest rate. |
3. Important notes when appealing Singapore corporate tax
Tax appeal is an important process for businesses to protect their rights when they disagree with a tax decision of the Inland Revenue Authority of Singapore (IRAS). To ensure the appeal process is effective and successful, businesses need to note the following important points:
3.1 Comply with the deadline for filing an appeal
- Businesses have only 2 months from the date of receipt of the Notice of Assessment to file an appeal.
- If more time is needed to collect documents, an extension may be requested, but the request must be submitted 2 months before the expiration date.
- If the deadline is missed, the business will lose its right to appeal and the tax amount in the NOA will be considered final and cannot be changed.
3.2 Ensure the appeal is valid
- The appeal must have specific and clear content, including:
- Year of Assessment (YA).
- Tax item is objected.
- Amount involved.
- Specific reasons and legal/business justification why the item should be adjusted.
- IRAS may reject appeals if information is missing or reasons are not given.
3.3 Use appropriate channels of appeal
- IRAS encourages businesses to submit their objections via the myTax Portal ("Revise/Object to Assessment" service) to receive a prompt response.
- The Objection Form can be sent via myTax Mail or post.
- If submitting by mail/email, ensure that the application is complete and accurate to avoid rejection.
3.4 Provide complete supporting documentation
- To increase the chances of success, businesses need to prepare clear supporting documents, such as:
- Invoices, contracts, meeting minutes, accounting documents.
- Audit report, financial report.
- Proof of property ownership or sales contract.
- Submitting incomplete documentation may result in IRAS rejecting the appeal or prolonging the review process.
3.5 Respond promptly when IRAS requests additional information
- During the review phase, IRAS may request further information from the business.
- The standard response time is 2 months from the date of IRAS's request.
- If the business fails to respond within the time limit, IRAS may decide to maintain the original tax rate and the business will lose its right to appeal further.
3.6 Prepare a next plan if the appeal is rejected
- If IRAS issues a "Notice of Refusal to Amend", the business can continue to appeal to the Income Tax Board of Review (ITBR) within 30 days.
- If you disagree with the ITBR's decision, you can appeal to the High Court or the Court of Appeal.
- Consider the importance of the case to decide whether to continue litigation.
3.7 Consider consulting a tax professional
- If a business is unsure about the appeals process or does not have the expertise to gather supporting documentation, it should seek the assistance of a tax professional.
- Tax professionals can help businesses:
- Assess the merits of the appeal before filing.
- Prepare complete documentation to increase the success rate.
- Guidance on the appeal process to court if necessary.
3.8 Keep complete tax records and related documents
- IRAS may request to inspect tax documents during the appeal process.
- Businesses should keep tax records for at least 5 years for easy retrieval when needed.
- Important documents to keep include:
- Financial report.
- Invoices, accounting documents.
- Correspondence with IRAS.
4. How does GLA support businesses in tax appeals against Singapore companies?
GLA supports businesses in tax appeals against Singapore companies through the following steps and services:
- Thoroughly review the business's tax records, including tax returns, financial statements, and other relevant documents.
- Legal advice on Singapore corporate tax appeal matters.
- Analyze relevant tax regulations and case law to determine the legal basis for appeal, and then assess the risks and benefits of appeal.
- Support Enterprises in collecting necessary documents to prove the appeal argument.
- Support businesses in submitting appeal documents to the Singapore tax authority (IRAS) in accordance with regulations.
- Support Business Declaration Singapore corporate tax accounting in accordance with IRAS regulations.
5. Frequently asked questions about tax appeals with Singapore companies
In what cases can a business appeal taxes?
Businesses can appeal if they disagree with a Notice of Assessment (NOA) from IRAS, including:
- Tax rate is incorrect.
- Revenue was miscalculated.
- Tax deductions are denied.
- Tax incentives not applied correctly.
What is the deadline for filing an appeal?
2 months from the date of receipt of NOA. If more time is needed, the business can request an extension.
Where can businesses file an appeal?
There are 3 ways:
- Via myTax Portal (recommended).
- Submit the Objection Form via myTax Mail or post.
- Send a letter/email stating the reason for the appeal.
What is required for a valid appeal?
The application must include:
- Year of assessment (YA).
- Tax item is objected.
- Amount involved.
- Reason for appeal and supporting documents (financial statements, invoices, contracts, etc.).
How long does it take for IRAS to process a tax appeal?
Usually within 6 months of receiving all information. Complex cases may take longer.
If IRAS rejects an appeal, what should a business do?
Businesses can:
- File a complaint with the Tax Review Board (ITBR) within 30 days.
- If you disagree with the ITBR's decision, you can appeal to the High Court or the Court of Appeal.
What are the common mistakes that cause appeals to be rejected?
- Late submission.
- No reason for appeal given.
- Lack of supporting documents.
- Failure to respond to IRAS requests for additional information.
Should businesses seek tax expert support in their appeal?
Yes, especially if:
- Tax filing is complicated.
- The tax amount was misassessed.
- Businesses are unclear about the process of working with IRAS.
Highlights- Businesses have the right to appeal against tax if they disagree with a Notice of Assessment (NOA) from IRAS, but must file the application within 2 months from the date of receipt of the NOA.
- A valid appeal must have specific reasons and sufficient supporting documentation (financial statements, contracts, invoices, etc.). Lack of information may result in rejection of the appeal.
- The appeals process consists of four stages: Application, review, litigation (if necessary), and finalisation. If IRAS refuses to make an adjustment, the business can appeal to the Tax Review Board (ITBR) and the High Court.
- GLA provides comprehensive support from tax declaration, tax appeal to working with IRAS, helping businesses optimize tax costs and protect their best interests.
This article was published by GLA on 29/08/2018. Copyright and accompanying content are intellectual property of GLA. All rights reserved.
The guidance and content are for general information only and are not intended to provide specific guidance and advice on accounting, tax, legal or other professional advice. Readers should consult professional advisors on specific issues.
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