Time within which payment is to be made
85.—(1) Subject to section 91, tax for any year of assessment levied in accordance with the provisions of this Act is, despite any objection or appeal against the assessment on which the tax is levied, payable at the place stated in the notice given under section 76 within one month after the service of the notice.(2) The Comptroller may, in his or her discretion and subject to such terms and conditions, including the imposition of interest, as he or she may impose, extend the time limit within which payment is to be made.
—(1) Subject to section 91, tax for any year of assessment levied in accordance with the provisions of this Act is, despite any objection or appeal against the assessment on which the tax is levied, payable at the place stated in the notice given under section 76 within one month after the service of the notice.
(2) The Comptroller may, in his or her discretion and subject to such terms and conditions, including the imposition of interest, as he or she may impose, extend the time limit within which payment is to be made.
Recovery of tax from persons leaving Singapore
86.—(1) Where the Comptroller is of the opinion that any person is about or likely to leave Singapore without paying all tax assessed upon the person, the Comptroller may issue a certificate containing particulars of such tax and a direction to the Commissioner of Police or the Controller of Immigration, or both, that such person be prevented from leaving Singapore without paying the tax or furnishing security to the Comptroller’s satisfaction for payment thereof.(2) Subject to the provisions of any order issued or made under any law for the time being in force relating to banishment or immigration, the Commissioner of Police or the Controller of Immigration, or both, as the case may be, must thereupon take, or cause to be taken by any police officer or immigration officer, such measures as may be necessary to prevent the person named in the direction from leaving Singapore until payment of the tax has been made or secured as aforesaid, including the use of such force as may be necessary and, if appropriate, the detention of any passport, certificate of identity or travel document and any exit permit or other document authorising such person to leave Singapore.
(3) At the time of issue of the certificate, the Comptroller must issue to such person a notification thereof; but the non‑receipt thereof does not invalidate any proceedings under this section.[Act 33 of 2022 wef 04/11/2022]
(4) Payment of the tax to an officer in charge of a police station or to an immigration officer or production of a certificate signed by the Comptroller, a Deputy Comptroller or an Assistant Comptroller stating that the tax has been paid or secured is sufficient authority for allowing such person to leave Singapore.
(5) Any person who, knowing that a direction has been issued under this section for the prevention of the person’s departure from Singapore, voluntarily leaves or attempts to leave Singapore without paying all tax assessed upon the person or furnishing security to the Comptroller’s satisfaction for payment thereof shall be guilty of an offence and may be arrested, without warrant, by any police officer or immigration officer.
(6) No civil or criminal proceedings may be instituted or maintained against the Government, the Commissioner of Police, the Controller of Immigration or any other police officer or immigration officer, in respect of anything lawfully done under the authority of this section.
(7) In this section, “tax” includes any interest imposed under section 85(2).
—(1) Where the Comptroller is of the opinion that any person is about or likely to leave Singapore without paying all tax assessed upon the person, the Comptroller may issue a certificate containing particulars of such tax and a direction to the Commissioner of Police or the Controller of Immigration, or both, that such person be prevented from leaving Singapore without paying the tax or furnishing security to the Comptroller’s satisfaction for payment thereof.
(2) Subject to the provisions of any order issued or made under any law for the time being in force relating to banishment or immigration, the Commissioner of Police or the Controller of Immigration, or both, as the case may be, must thereupon take, or cause to be taken by any police officer or immigration officer, such measures as may be necessary to prevent the person named in the direction from leaving Singapore until payment of the tax has been made or secured as aforesaid, including the use of such force as may be necessary and, if appropriate, the detention of any passport, certificate of identity or travel document and any exit permit or other document authorising such person to leave Singapore.
(3) At the time of issue of the certificate, the Comptroller must issue to such person a notification thereof; but the non‑receipt thereof does not invalidate any proceedings under this section.[Act 33 of 2022 wef 04/11/2022]
(4) Payment of the tax to an officer in charge of a police station or to an immigration officer or production of a certificate signed by the Comptroller, a Deputy Comptroller or an Assistant Comptroller stating that the tax has been paid or secured is sufficient authority for allowing such person to leave Singapore.
(5) Any person who, knowing that a direction has been issued under this section for the prevention of the person’s departure from Singapore, voluntarily leaves or attempts to leave Singapore without paying all tax assessed upon the person or furnishing security to the Comptroller’s satisfaction for payment thereof shall be guilty of an offence and may be arrested, without warrant, by any police officer or immigration officer.
(6) No civil or criminal proceedings may be instituted or maintained against the Government, the Commissioner of Police, the Controller of Immigration or any other police officer or immigration officer, in respect of anything lawfully done under the authority of this section.
(7) In this section, “tax” includes any interest imposed under section 85(2).
Penalty for non‑payment of tax and enforcement of payment
87.—(1) Subject to subsection (2), if any tax is not paid within the periods prescribed in section 85 —(a)
a sum equal to 5% of the amount of tax payable is added thereto, and the provisions of this Act relating to the collection and recovery of tax apply to the collection and recovery of such sum;
(b)
the Comptroller must serve a demand note upon the person assessed and if payment is not made within one month from the date of the service of such demand note, the Comptroller may proceed to enforce payment as hereinafter provided;
(c)
despite paragraphs (a) and (b), if the amount of tax outstanding is not paid within 60 days of the imposition of the penalty as provided by paragraph (a), an additional penalty of 1% of the tax outstanding is payable for each completed month that the tax remains unpaid, but the total additional penalty must not exceed 12% of the amount of tax outstanding, and the provisions of this Act relating to the collection and recovery of tax apply to the collection and recovery of such additional penalty; and
(d)
penalties imposed under paragraphs (a), (b) and (c) are not deemed to be part of the tax paid for the purpose of claiming relief under any of the provisions of this Act.
(2) The Comptroller may for any good cause shown remit the whole or any part of the penalty due under subsection (1).
(3) In this section, “tax” includes any interest imposed under section 85(2).
—(1) Subject to subsection (2), if any tax is not paid within the periods prescribed in section 85 —(a)
a sum equal to 5% of the amount of tax payable is added thereto, and the provisions of this Act relating to the collection and recovery of tax apply to the collection and recovery of such sum;
(b)
the Comptroller must serve a demand note upon the person assessed and if payment is not made within one month from the date of the service of such demand note, the Comptroller may proceed to enforce payment as hereinafter provided;
(c)
despite paragraphs (a) and (b), if the amount of tax outstanding is not paid within 60 days of the imposition of the penalty as provided by paragraph (a), an additional penalty of 1% of the tax outstanding is payable for each completed month that the tax remains unpaid, but the total additional penalty must not exceed 12% of the amount of tax outstanding, and the provisions of this Act relating to the collection and recovery of tax apply to the collection and recovery of such additional penalty; and
(d)
penalties imposed under paragraphs (a), (b) and (c) are not deemed to be part of the tax paid for the purpose of claiming relief under any of the provisions of this Act.
(2) The Comptroller may for any good cause shown remit the whole or any part of the penalty due under subsection (1).
(3) In this section, “tax” includes any interest imposed under section 85(2).
Change of address
88.—(1) Subject to subsection (2), every person liable to pay income tax under the provisions of this Act must inform the Comptroller in writing of any change in the person’s address.(2) Where a person liable to pay income tax uses his or her residential address for the purposes of this Act, then, if the person has changed his or her residential address and has made a report of the change under section 10 of the National Registration Act 1965 —(a)
the person is deemed to have informed the Comptroller of the change of his or her residential address in compliance with subsection (1); and
(b)
the new residential address as reported by the person under section 10 of the National Registration Act 1965 is, unless the person informs the Comptroller in writing to the contrary, deemed to be his or her last known address for the purpose of subsection (3).
(3) Any notice or process given or served upon any person by posting the same or a copy thereof by registered post to the person at his or her last known address is, despite section 8(3), deemed to have been duly given or served and is conclusive evidence of the fact of service.
—(1) Subject to subsection (2), every person liable to pay income tax under the provisions of this Act must inform the Comptroller in writing of any change in the person’s address.
(2) Where a person liable to pay income tax uses his or her residential address for the purposes of this Act, then, if the person has changed his or her residential address and has made a report of the change under section 10 of the National Registration Act 1965 —(a)
the person is deemed to have informed the Comptroller of the change of his or her residential address in compliance with subsection (1); and
(b)
the new residential address as reported by the person under section 10 of the National Registration Act 1965 is, unless the person informs the Comptroller in writing to the contrary, deemed to be his or her last known address for the purpose of subsection (3).
(3) Any notice or process given or served upon any person by posting the same or a copy thereof by registered post to the person at his or her last known address is, despite section 8(3), deemed to have been duly given or served and is conclusive evidence of the fact of service.
Suit for tax by Comptroller
89.—(1) Despite the provisions of any other written law, tax, interest and any penalty imposed under this Act and any sum due to the Government under section 45 or 45EA, may be sued for by way of a specially endorsed originating claim.[37/2014]
[Act 25 of 2021 wef 01/04/2022]
(2) The Comptroller may, in his or her own name, sue for any such tax, interest, penalty or other sum due and is entitled to all costs allowed by law against the person liable thereto.
(3) The Comptroller may appear personally or by counsel in any suit instituted under this section.
(4) In any suit under this section, the production of a certificate signed by the Comptroller giving the name and address of the defendant and the amount of tax, interest or penalty due by the defendant is sufficient evidence of the amount so due and sufficient authority for the court to give judgment for that amount.
(5) In addition to any other powers of collection and recovery provided in this Act, the Comptroller may, with the approval of the Minister and, where the tax charged on the income of any person who carries on the business of shipowner or charterer or of air transport has been in default for more than 3 months, whether the person is assessed directly or in the name of some other person, issue to the Director‑General of Customs, or other authority by whom clearance may be granted, a certificate containing the name or names of the person and particulars of the tax in default.
(6) On receipt of such a certificate, the Director‑General of Customs or other authority is empowered and required to refuse clearance from any port, aerodrome or airport in Singapore to any ship or aircraft owned wholly or partly or chartered by that person until the tax has been paid.
(7) No civil or criminal proceedings may be instituted or maintained against the Government, the Director‑General of Customs or other authority in respect of a refusal of clearance under this section, nor does the fact that a ship or an aircraft is detained under this section affect the liability of the owner, charterer, or agent to pay harbour or other dues and charges for the period of detention.
(8) In subsections (6) and (7), “ship” has the meaning given by section 2(1) of the Merchant Shipping Act 1995.[2/2016]
—(1) Despite the provisions of any other written law, tax, interest and any penalty imposed under this Act and any sum due to the Government under section 45 or 45EA, may be sued for by way of a specially endorsed originating claim.[37/2014]
[Act 25 of 2021 wef 01/04/2022]
(2) The Comptroller may, in his or her own name, sue for any such tax, interest, penalty or other sum due and is entitled to all costs allowed by law against the person liable thereto.
(3) The Comptroller may appear personally or by counsel in any suit instituted under this section.
(4) In any suit under this section, the production of a certificate signed by the Comptroller giving the name and address of the defendant and the amount of tax, interest or penalty due by the defendant is sufficient evidence of the amount so due and sufficient authority for the court to give judgment for that amount.
(5) In addition to any other powers of collection and recovery provided in this Act, the Comptroller may, with the approval of the Minister and, where the tax charged on the income of any person who carries on the business of shipowner or charterer or of air transport has been in default for more than 3 months, whether the person is assessed directly or in the name of some other person, issue to the Director‑General of Customs, or other authority by whom clearance may be granted, a certificate containing the name or names of the person and particulars of the tax in default.
(6) On receipt of such a certificate, the Director‑General of Customs or other authority is empowered and required to refuse clearance from any port, aerodrome or airport in Singapore to any ship or aircraft owned wholly or partly or chartered by that person until the tax has been paid.
(7) No civil or criminal proceedings may be instituted or maintained against the Government, the Director‑General of Customs or other authority in respect of a refusal of clearance under this section, nor does the fact that a ship or an aircraft is detained under this section affect the liability of the owner, charterer, or agent to pay harbour or other dues and charges for the period of detention.
(8) In subsections (6) and (7), “ship” has the meaning given by section 2(1) of the Merchant Shipping Act 1995.[2/2016]
Statement of Comptroller sufficient
90.—(1) In any civil or criminal proceedings under this Act, every statement purporting to be under the hand of the Comptroller contained in the information, complaint, declaration or claim is prima facie evidence of the matter stated therein.(2) This section applies to any matter so stated although —(a)
evidence in support or rebuttal of the matter stated or of any other matter is given; or
(b)
the matter stated is a mixed question of law and fact, but in such case the statement is prima facie evidence of the fact only.
(3) This section does not apply to —(a)
a statement of the intent of the defendant; or
(b)
proceedings for an offence punishable by imprisonment.
—(1) In any civil or criminal proceedings under this Act, every statement purporting to be under the hand of the Comptroller contained in the information, complaint, declaration or claim is prima facie evidence of the matter stated therein.
(2) This section applies to any matter so stated although —(a)
evidence in support or rebuttal of the matter stated or of any other matter is given; or
(b)
the matter stated is a mixed question of law and fact, but in such case the statement is prima facie evidence of the fact only.
(3) This section does not apply to —(a)
a statement of the intent of the defendant; or
(b)
proceedings for an offence punishable by imprisonment.
Deduction of tax from emoluments and pensions
91.—(1) Where any income chargeable under section 10(1)(b) or (e) is payable to any individual, deductions on account of tax which is or will be payable by the individual for any year of assessment must, if the Comptroller so directs, be made out of the income or any arrears thereof.(2) Subject to any rules made under section 7, deductions authorised by this section must be made at such times and in such amounts as the Comptroller directs whether or not the tax has been assessed; except that if on the assessment becoming final and conclusive it appears that the deductions made exceed the tax payable, the tax overpaid by means of the previous deductions must be repaid.
(3) Where any deduction has been made from the income so chargeable of any individual, the individual has the same right of objection or appeal against the deduction as he or she has against an assessment made upon him or her.
(4) Any amount deducted pursuant to any direction given by the Comptroller under this section must be paid by the employer to the Comptroller within 10 days after the date of the deduction, and if any such amount is not paid —(a)
within that period of 10 days, a penalty equal to 5% of that amount is payable by the employer to the Comptroller;
(b)
within one month after the date of the deduction, an additional penalty equal to 1% of that amount is payable by the employer to the Comptroller for each completed month that the amount remains unpaid, but the total additional penalty must not exceed 12% of the amount outstanding.
(5) The Comptroller may for any good cause shown remit the whole or any part of the penalty due under subsection (4).
(6) If and so far as any such income is paid without deduction of tax as aforesaid, the tax may be collected and payment thereof enforced in accordance with sections 85, 86 and 87.
(7) For the purpose of section 85, the Comptroller must determine the period within which the tax is payable.
(8) An employer who fails to comply with section 68(7) is liable to pay the full amount of the tax which by reason of such failure cannot be recovered from such employee.
(9) The Comptroller must apply any amount recovered by or paid to him or her in or towards payment of the tax payable by the employee.
(10) The employer may recover from the employee any amount which the employer has paid to the Comptroller or which has been recovered from the employer by the Comptroller under subsection (8).
(11) Any partner who fails to comply with section 68(11) is liable to pay the amount of the tax which by reason of such failure cannot be recovered from the person who has ceased to be a partner.
(12) The liability of a remaining partner under subsection (11) must not exceed the amount paid by that partner in contravention of section 68(11).
(13) Subsection (11) does not preclude a partner who pays any amount of tax under that subsection from recovering such amount from the person who has ceased to be a partner.
—(1) Where any income chargeable under section 10(1)(b) or (e) is payable to any individual, deductions on account of tax which is or will be payable by the individual for any year of assessment must, if the Comptroller so directs, be made out of the income or any arrears thereof.
(2) Subject to any rules made under section 7, deductions authorised by this section must be made at such times and in such amounts as the Comptroller directs whether or not the tax has been assessed; except that if on the assessment becoming final and conclusive it appears that the deductions made exceed the tax payable, the tax overpaid by means of the previous deductions must be repaid.
(3) Where any deduction has been made from the income so chargeable of any individual, the individual has the same right of objection or appeal against the deduction as he or she has against an assessment made upon him or her.
(4) Any amount deducted pursuant to any direction given by the Comptroller under this section must be paid by the employer to the Comptroller within 10 days after the date of the deduction, and if any such amount is not paid —(a)
within that period of 10 days, a penalty equal to 5% of that amount is payable by the employer to the Comptroller;
(b)
within one month after the date of the deduction, an additional penalty equal to 1% of that amount is payable by the employer to the Comptroller for each completed month that the amount remains unpaid, but the total additional penalty must not exceed 12% of the amount outstanding.
(5) The Comptroller may for any good cause shown remit the whole or any part of the penalty due under subsection (4).
(6) If and so far as any such income is paid without deduction of tax as aforesaid, the tax may be collected and payment thereof enforced in accordance with sections 85, 86 and 87.
(7) For the purpose of section 85, the Comptroller must determine the period within which the tax is payable.
(8) An employer who fails to comply with section 68(7) is liable to pay the full amount of the tax which by reason of such failure cannot be recovered from such employee.
(9) The Comptroller must apply any amount recovered by or paid to him or her in or towards payment of the tax payable by the employee.
(10) The employer may recover from the employee any amount which the employer has paid to the Comptroller or which has been recovered from the employer by the Comptroller under subsection (8).
(11) Any partner who fails to comply with section 68(11) is liable to pay the amount of the tax which by reason of such failure cannot be recovered from the person who has ceased to be a partner.
(12) The liability of a remaining partner under subsection (11) must not exceed the amount paid by that partner in contravention of section 68(11).
(13) Subsection (11) does not preclude a partner who pays any amount of tax under that subsection from recovering such amount from the person who has ceased to be a partner.
Remission, reduction or refund of tax
92.—(1) The Comptroller may remit, wholly or in part, the tax payable by any person on the ground of poverty.(2) The Minister may at any time, in his or her discretion and subject to such conditions as the Minister may impose, remit, reduce or refund, wholly or in part, the tax that is or will be payable or that is paid by any person.
(2A) The Minister may, by order in the Gazette, remit, reduce or refund, wholly or in part, the tax that is or will be payable or that is paid by any class of persons, subject to such conditions as the Minister may specify in the order.
(2B) Where the Minister is satisfied that a person to whom a remission, reduction or refund of tax is granted fails to comply with any condition imposed under subsection (2) or (2A) (whether a condition precedent or condition subsequent), an amount equal to the amount of tax so remitted, reduced or refunded is recoverable as a debt due to the Government.
(2C) The amount recoverable under subsection (2B) is payable at the place stated in a notice served by the Comptroller on the person within one month after the service of the notice.
(2D) The Comptroller may, in his or her discretion and subject to such terms and conditions (including the imposition of interest) as the Comptroller may impose, extend the time limit within which payment is to be made.
(2E) Sections 86(1) to (6), 87(1) and (2), 89, 90 and 91 apply to the collection and recovery by the Comptroller of the amount recoverable under subsection (2B) and any interest imposed under subsection (2D) as they apply to the collection and recovery of tax.
(3) [Deleted by Act 19 of 2013]
(4) The Minister may make rules for the purpose of giving effect to this section.
—(1) The Comptroller may remit, wholly or in part, the tax payable by any person on the ground of poverty.
(2) The Minister may at any time, in his or her discretion and subject to such conditions as the Minister may impose, remit, reduce or refund, wholly or in part, the tax that is or will be payable or that is paid by any person.
(2A) The Minister may, by order in the Gazette, remit, reduce or refund, wholly or in part, the tax that is or will be payable or that is paid by any class of persons, subject to such conditions as the Minister may specify in the order.
(2B) Where the Minister is satisfied that a person to whom a remission, reduction or refund of tax is granted fails to comply with any condition imposed under subsection (2) or (2A) (whether a condition precedent or condition subsequent), an amount equal to the amount of tax so remitted, reduced or refunded is recoverable as a debt due to the Government.
(2C) The amount recoverable under subsection (2B) is payable at the place stated in a notice served by the Comptroller on the person within one month after the service of the notice.
(2D) The Comptroller may, in his or her discretion and subject to such terms and conditions (including the imposition of interest) as the Comptroller may impose, extend the time limit within which payment is to be made.
(2E) Sections 86(1) to (6), 87(1) and (2), 89, 90 and 91 apply to the collection and recovery by the Comptroller of the amount recoverable under subsection (2B) and any interest imposed under subsection (2D) as they apply to the collection and recovery of tax.
(3) [Deleted by Act 19 of 2013]
(4) The Minister may make rules for the purpose of giving effect to this section.
Remission of tax of companies for year of assessment 2011
92A.—(1) Subject to subsection (2), there is to be remitted the tax payable for the year of assessment 2011 by a company an amount equal to the lower of —(a)
20% of the tax payable for that year of assessment (excluding any tax levied and paid or payable pursuant to section 43(3), (3A) and (3B)); and
(b)
$10,000,
where the Comptroller is satisfied that the remission of tax would be beneficial to the company.
(2) No remission under subsection (1) may be granted to a company where the company qualifies for the cash grant under section 92B.
—(1) Subject to subsection (2), there is to be remitted the tax payable for the year of assessment 2011 by a company an amount equal to the lower of —(a)
20% of the tax payable for that year of assessment (excluding any tax levied and paid or payable pursuant to section 43(3), (3A) and (3B)); and
(b)
$10,000,
where the Comptroller is satisfied that the remission of tax would be beneficial to the company.
(2) No remission under subsection (1) may be granted to a company where the company qualifies for the cash grant under section 92B.
Cash grant for companies for year of assessment 2011
92B.—(1) Where a company has made a contribution to the Central Provident Fund in respect of any of its employees during the basis period for the year of assessment 2011, and —(a)
the company is not liable to pay tax for the year of assessment 2011;
(b)
the specified amount is greater than 20% of the tax payable by the company for that year of assessment (excluding any tax levied and paid or payable pursuant to section 43(3), (3A) and (3B)); or
(c)
the company makes a written election for a cash grant under this section in lieu of the remission under section 92A, and the Comptroller is satisfied that the cash grant would be more beneficial to the company than the remission,
then there is, in lieu of the remission of tax under section 92A, to be made to the company for the year of assessment 2011 a cash grant of the specified amount.
(2) The election under subsection (1)(c) must be made to the Comptroller at the time the company furnishes a return of its income for the year of assessment 2011 or within such further time as the Comptroller may allow.
(3) The cash grant under subsection (1) is exempt from tax in the hands of the company.
(4) Where a company receives a cash grant under subsection (1) —(a)
without having satisfied all the requirements in this section; or
(b)
that is in excess of that which may be given to it under this section,
the amount of the cash grant or the excess amount of the cash grant (as the case may be) is recoverable by the Comptroller from the company as a debt due to the Government.
(5) The Comptroller must send the company a notice specifying the amount to be repaid under subsection (4), and the company must pay the amount at the place stated in the notice within one month after the service of the notice.
(6) The Comptroller may, in his or her discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment under subsection (5) is to be made.
(7) Sections 86(1) to (6), 87(1) and (2), 89, 90 and 91 apply to the collection and recovery by the Comptroller of the amounts recoverable under subsection (5) as they apply to the collection and recovery of tax.
(8) Where any tax, duty, interest or penalty is due by the company —(a)
under this Act to the Comptroller of Income Tax;
(b)
under the Goods and Services Tax Act 1993 to the Comptroller of Goods and Services Tax;
(c)
under the Property Tax Act 1960 to the Comptroller of Property Tax; or
(d)
under the Stamp Duties Act 1929 to the Commissioner of Stamp Duties,
then the amount of cash grant made by the Comptroller to the company must be reduced by the amount so due; and the amount of the reduction is deemed to be tax, duty, interest or penalty paid by the company under the relevant Act and must (if it is due under an Act other than this Act) be paid by the Comptroller to the Comptroller of Goods and Services Tax, the Comptroller of Property Tax or the Commissioner of Stamp Duties, as the case may be.
(9) In this section, “specified amount” means —(a)
5% of the gross amount of the income derived by a company from its principal activities in the basis period for the year of assessment 2011; or
(b)
$5,000,
whichever is the lower.
—(1) Where a company has made a contribution to the Central Provident Fund in respect of any of its employees during the basis period for the year of assessment 2011, and —(a)
the company is not liable to pay tax for the year of assessment 2011;
(b)
the specified amount is greater than 20% of the tax payable by the company for that year of assessment (excluding any tax levied and paid or payable pursuant to section 43(3), (3A) and (3B)); or
(c)
the company makes a written election for a cash grant under this section in lieu of the remission under section 92A, and the Comptroller is satisfied that the cash grant would be more beneficial to the company than the remission,
then there is, in lieu of the remission of tax under section 92A, to be made to the company for the year of assessment 2011 a cash grant of the specified amount.
(2) The election under subsection (1)(c) must be made to the Comptroller at the time the company furnishes a return of its income for the year of assessment 2011 or within such further time as the Comptroller may allow.
(3) The cash grant under subsection (1) is exempt from tax in the hands of the company.
(4) Where a company receives a cash grant under subsection (1) —(a)
without having satisfied all the requirements in this section; or
(b)
that is in excess of that which may be given to it under this section,
the amount of the cash grant or the excess amount of the cash grant (as the case may be) is recoverable by the Comptroller from the company as a debt due to the Government.
(5) The Comptroller must send the company a notice specifying the amount to be repaid under subsection (4), and the company must pay the amount at the place stated in the notice within one month after the service of the notice.
(6) The Comptroller may, in his or her discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment under subsection (5) is to be made.
(7) Sections 86(1) to (6), 87(1) and (2), 89, 90 and 91 apply to the collection and recovery by the Comptroller of the amounts recoverable under subsection (5) as they apply to the collection and recovery of tax.
(8) Where any tax, duty, interest or penalty is due by the company —(a)
under this Act to the Comptroller of Income Tax;
(b)
under the Goods and Services Tax Act 1993 to the Comptroller of Goods and Services Tax;
(c)
under the Property Tax Act 1960 to the Comptroller of Property Tax; or
(d)
under the Stamp Duties Act 1929 to the Commissioner of Stamp Duties,
then the amount of cash grant made by the Comptroller to the company must be reduced by the amount so due; and the amount of the reduction is deemed to be tax, duty, interest or penalty paid by the company under the relevant Act and must (if it is due under an Act other than this Act) be paid by the Comptroller to the Comptroller of Goods and Services Tax, the Comptroller of Property Tax or the Commissioner of Stamp Duties, as the case may be.
(9) In this section, “specified amount” means —(a)
5% of the gross amount of the income derived by a company from its principal activities in the basis period for the year of assessment 2011; or
(b)
$5,000,
whichever is the lower.
Cash grant for companies for year of assessment 2012
92C.—(1) Where a company carrying on business in Singapore has made a contribution to the Central Provident Fund in respect of at least one of its qualifying employees during the basis period for the year of assessment 2012, there is to be made to the company for the year of assessment 2012 a cash grant of —(a)
5% of the gross amount of the income derived by the company from its principal activities in the basis period for the year of assessment 2012; or
(b)
$5,000,
whichever is the lower.
(2) No cash grant under subsection (1) may be made if the company has ceased to carry on business in Singapore.
(3) The Minister may waive the requirement under subsection (1) in respect of the contribution to the Central Provident Fund by the company if the Minister is satisfied that it is just and equitable to do so.
(4) The cash grant under subsection (1) is exempt from tax in the hands of the company.
(5) Section 92B(4) to (8) applies, with the necessary modifications, to this section.
(6) In this section, “qualifying employee” means an employee of the company based on the payroll for any month within its basis period for the year of assessment 2012, but excludes any employee who is also a shareholder of the company.
(7) In the application (by virtue of section 36B) of this section to a registered business trust, a reference to a contribution by a company to the Central Provident Fund in respect of at least one of its qualifying employees is a reference to a contribution by the trustee‑manager of the business trust to the Central Provident Fund in respect of at least one of its employees, being one —(a)
who is an employee of the trustee‑manager according to the payroll for any month within the basis period of the trust for the year of assessment 2012; and
(b)
whose sole duty is assisting in managing or operating the trust,
but excluding any employee who is also a unitholder of the trust.
—(1) Where a company carrying on business in Singapore has made a contribution to the Central Provident Fund in respect of at least one of its qualifying employees during the basis period for the year of assessment 2012, there is to be made to the company for the year of assessment 2012 a cash grant of —(a)
5% of the gross amount of the income derived by the company from its principal activities in the basis period for the year of assessment 2012; or
(b)
$5,000,
whichever is the lower.
(2) No cash grant under subsection (1) may be made if the company has ceased to carry on business in Singapore.
(3) The Minister may waive the requirement under subsection (1) in respect of the contribution to the Central Provident Fund by the company if the Minister is satisfied that it is just and equitable to do so.
(4) The cash grant under subsection (1) is exempt from tax in the hands of the company.
(5) Section 92B(4) to (8) applies, with the necessary modifications, to this section.
(6) In this section, “qualifying employee” means an employee of the company based on the payroll for any month within its basis period for the year of assessment 2012, but excludes any employee who is also a shareholder of the company.
(7) In the application (by virtue of section 36B) of this section to a registered business trust, a reference to a contribution by a company to the Central Provident Fund in respect of at least one of its qualifying employees is a reference to a contribution by the trustee‑manager of the business trust to the Central Provident Fund in respect of at least one of its employees, being one —(a)
who is an employee of the trustee‑manager according to the payroll for any month within the basis period of the trust for the year of assessment 2012; and
(b)
whose sole duty is assisting in managing or operating the trust,
but excluding any employee who is also a unitholder of the trust.
Remission of tax of companies for years of assessment 2013, 2014 and 2015
92D. Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for each of the years of assessment 2013, 2014 and 2015 by the company of an amount equal to the lower of the following:(a)
30% of the tax payable for that year of assessment (excluding any tax levied and paid or payable pursuant to section 43(3), (3A) and (3B));
(b)
$30,000.
Remission of tax of companies for year of assessment 2016
92E. Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2016 by the company of an amount equal to the lower of the following:(a)
50% of the tax payable for that year of assessment (excluding any tax levied and paid or payable pursuant to section 43(3), (3A) and (3B));
(b)
$20,000.[2/2016; 34/2016; 39/2017]
Remission of tax of companies for year of assessment 2017
92F. Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2017 by the company of an amount equal to the lower of the following:(a)
50% of the tax payable for that year of assessment (excluding any tax levied and paid or payable pursuant to section 43(3), (3A) and (3B));
(b)
$25,000.[39/2017]
Remission of tax of companies for year of assessment 2018
92G. Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2018 by the company of an amount equal to the lower of the following:(a)
40% of the tax payable for that year of assessment (excluding any tax levied and paid or payable pursuant to section 43(3), (3A) and (3B));
(b)
$15,000.[39/2017; 45/2018]
Remission of tax of companies for year of assessment 2019
92H. Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2019 by the company of an amount equal to the lower of the following:(a)
20% of the tax payable for that year of assessment (excluding any tax levied and paid or payable pursuant to section 43(3), (3A) and (3B));
(b)
$10,000.[45/2018]
Remission of tax of companies for year of assessment 2020
92I. Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2020 by the company of an amount equal to the lower of the following:(a)
25% of the tax payable for that year of assessment (excluding any tax levied and paid or payable pursuant to section 43(3), (3A) and (3B));
(b)
$15,000.[41/2020]
Remission of tax for companies for year of assessment 2024 and cash grant for companies
92J.—(1) Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2024 by the company of an amount equal to the lower of the following:(a)
50% of the tax payable for that year of assessment (excluding any tax levied under section 43(3), (3A), (3B) and (3C)), less the cash grant of $2,000 made to the company under subsection (3), where applicable;
(b)
$40,000, less the cash grant of $2,000 made to the company under subsection (3), where applicable.
(2) However, where 50% of the tax payable under subsection (1)(a) is less than the cash grant of $2,000, the amount in subsection (1)(a) is nil.
(3) Where a company has made a CPF contribution in respect of at least one local employee in the calendar year 2023 in accordance with regulation 2(1) of the Central Provident Fund Regulations (Rg 15) (called in this section the time requirement), there is to be made to the company a cash grant of $2,000.
(4) The Comptroller may waive the time requirement under subsection (3) if the Comptroller is satisfied that it is just and equitable to do so.
(5) The cash grant under subsection (3) is exempt from tax in the hands of the company.
(6) Section 92B(4) to (8) applies, with the necessary modifications, to a cash grant made under this section.
(7) For the purpose of subsection (3) —“central hirer” and “central hiring arrangement” have the meanings given by section 14ZG(5);
“CPF contribution” means a contribution to the Central Provident Fund that is obligatory under section 7(1) of the Central Provident Fund Act 1953;
“employee”, in relation to a company, means —(a)
an individual who is an employee of the company for any period in the calendar year 2023 and is on the payroll of the company for that period;
(b)
an individual —(i)
who is engaged by the central hirer of a central hiring arrangement for a group of related parties that includes the company;
(ii)
who is deployed to work solely for the company for any period in the calendar year 2023;
(iii)
who is on the payroll of the central hirer or the company for that period; and
(iv)
whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company; or
(c)
an individual —(i)
who, being an employee of another person that is a related party of the company (called in this subsection and subsection (8) the employer), is seconded to a position in the company under a bona fide commercial arrangement to work solely for the company for any period in the calendar year 2023;
(ii)
who is on the payroll of the employer or the company for that period; and
(iii)
whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company,
but excludes any individual who is a shareholder and also a director of the company;
“local employee” means a Singapore citizen or Singapore permanent resident who is an employee of the company.
(8) For the purpose of determining whether the individual mentioned in paragraph (b) or (c) of the definition of “employee” in subsection (7) is also an employee of the central hirer or the employer by virtue of paragraph (a) of that definition, the period mentioned in paragraph (b) or (c) (as the case may be) is to be disregarded for the purpose of paragraph (a) of that definition.[Act 35 of 2024 wef 16/02/2024]
—(1) Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2024 by the company of an amount equal to the lower of the following:(a)
50% of the tax payable for that year of assessment (excluding any tax levied under section 43(3), (3A), (3B) and (3C)), less the cash grant of $2,000 made to the company under subsection (3), where applicable;
(b)
$40,000, less the cash grant of $2,000 made to the company under subsection (3), where applicable.
(2) However, where 50% of the tax payable under subsection (1)(a) is less than the cash grant of $2,000, the amount in subsection (1)(a) is nil.
(3) Where a company has made a CPF contribution in respect of at least one local employee in the calendar year 2023 in accordance with regulation 2(1) of the Central Provident Fund Regulations (Rg 15) (called in this section the time requirement), there is to be made to the company a cash grant of $2,000.
(4) The Comptroller may waive the time requirement under subsection (3) if the Comptroller is satisfied that it is just and equitable to do so.
(5) The cash grant under subsection (3) is exempt from tax in the hands of the company.
(6) Section 92B(4) to (8) applies, with the necessary modifications, to a cash grant made under this section.
(7) For the purpose of subsection (3) —“central hirer” and “central hiring arrangement” have the meanings given by section 14ZG(5);
“CPF contribution” means a contribution to the Central Provident Fund that is obligatory under section 7(1) of the Central Provident Fund Act 1953;
“employee”, in relation to a company, means —(a)
an individual who is an employee of the company for any period in the calendar year 2023 and is on the payroll of the company for that period;
(b)
an individual —(i)
who is engaged by the central hirer of a central hiring arrangement for a group of related parties that includes the company;
(ii)
who is deployed to work solely for the company for any period in the calendar year 2023;
(iii)
who is on the payroll of the central hirer or the company for that period; and
(iv)
whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company; or
(c)
an individual —(i)
who, being an employee of another person that is a related party of the company (called in this subsection and subsection (8) the employer), is seconded to a position in the company under a bona fide commercial arrangement to work solely for the company for any period in the calendar year 2023;
(ii)
who is on the payroll of the employer or the company for that period; and
(iii)
whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company,
but excludes any individual who is a shareholder and also a director of the company;
“local employee” means a Singapore citizen or Singapore permanent resident who is an employee of the company.
(8) For the purpose of determining whether the individual mentioned in paragraph (b) or (c) of the definition of “employee” in subsection (7) is also an employee of the central hirer or the employer by virtue of paragraph (a) of that definition, the period mentioned in paragraph (b) or (c) (as the case may be) is to be disregarded for the purpose of paragraph (a) of that definition.[Act 35 of 2024 wef 16/02/2024]
Rebate for company for listing shares on stock exchange in Singapore
92K.—(1) This section applies to a company the ordinary shares of which —(a)
are first listed on a stock exchange in Singapore on a date (called in this section the listing date) between 19 February 2025 and 31 December 2027 (both dates inclusive), by way of a primary listing or a secondary listing; and
(b)
are offered in conjunction with such listing.
(2) For the purposes of this section, the first listing of ordinary shares of a company on a stock exchange includes a relisting of ordinary shares of that company on that stock exchange, at any time after ordinary shares of that company have been delisted from that stock exchange.
Approval of approved company
(3) The company may apply to the Minister or an authorised body to be approved for the purposes of this section.
(4) An application under subsection (3) must be made within such period as the Minister or authorised body may allow, and must be accompanied by such information and documents as the Minister or authorised body may require.
(5) A company that is approved as a financial sector incentive company for the purposes of section 43J(1B), or its holding company, is not eligible to make an application under subsection (3).
(6) The Minister or authorised body may, subject to such conditions (including conditions subsequent) as the Minister or authorised body may impose, approve a company as an approved company for the purposes of this section.
(7) An approval under subsection (6) is for a single period of 5 years (called in this section the incentive period) starting from the first day of the month in which the listing date falls, and the earliest date on which an approval may take effect is 1 February 2025.
(8) It is a condition of approval of an approved company for its ordinary shares to remain listed on a stock exchange in Singapore throughout its incentive period, starting from its listing date.
(9) No approval under this section may be granted after 31 December 2027.
Tax rebate for approved company
(10) The following is to be made to an approved company:(a)
where its ordinary shares are listed on a stock exchange in Singapore by way of a primary listing in the whole or part of the basis period for a year of assessment that is within its incentive period — a rebate computed in accordance with the following formula:
where —
(i)
A is —(A)
where the ordinary shares are so listed in the whole of the basis period within its incentive period — the number of months in that basis period;
(B)
where only a part of the basis period during which the ordinary shares are so listed falls within its incentive period — the number of months in that part;
(C)
where the ordinary shares are so listed in a part of the basis period within its incentive period before the occurrence of a listing conversion — the number of months in that part before the month in which the listing conversion occurs; or
(D)
where the ordinary shares are so listed in a part of the basis period within its incentive period after the occurrence of a listing conversion — the number of months in that part beginning with the month in which the listing conversion occurs;
(ii)
B is the total number of months in the basis period; and
(iii)
C is the tax payable by the approved company for that year of assessment as determined under subsection (11);
(b)
where its ordinary shares are listed on a stock exchange in Singapore by way of a secondary listing in the whole or part of the basis period for a year of assessment that is within its incentive period — a rebate computed in accordance with the following formula:
where —
(i)
A is —(A)
where the ordinary shares are so listed in the whole of the basis period within its incentive period — the number of months in that basis period;
(B)
where only a part of the basis period during which the ordinary shares are so listed falls within its incentive period — the number of months in that part;
(C)
where the ordinary shares are so listed in a part of the basis period within its incentive period before the occurrence of a listing conversion — the number of months in that part before the month in which the listing conversion occurs; or
(D)
where the ordinary shares are so listed in a part of the basis period within its incentive period after the occurrence of a listing conversion — the number of months in that part beginning with the month in which the listing conversion occurs;
(ii)
B is the total number of months in the basis period; and
(iii)
C is the tax payable by the approved company for that year of assessment as determined under subsection (11).
(11) In subsection (10)(a)(iii) and (b)(iii), the tax payable by the approved company for a year of assessment is the amount of tax levied on the chargeable income of the approved company under Part 11 for that year of assessment (excluding any tax levied under section 43(3), (3A), (3B) and (3C)) —(a)
before making any set-off under Part 13;
(b)
before making any remission of the tax under any other provision of this Part; and
(c)
after making any deduction of tax credit under Part 14.
(12) The rebate to be made to an approved company against the tax payable for each year of assessment must not exceed —(a)
if the approved company has a market capitalisation of at least $1 billion on the listing date — $6 million; or
(b)
if the approved company has a market capitalisation of less than $1 billion on the listing date — $3 million.
(13) If a listing conversion occurs in the basis period for a year of assessment, then the maximum amount of rebate to be made to the approved company against the tax payable for that year of assessment is to be computed as follows:(a)
the rebate against the tax payable for that year of assessment, pro-rated for the period before the listing conversion, must not exceed an amount determined by , where —(i)
A is the amount mentioned in subsection (12)(a) or (b) (whichever is applicable);
(ii)
B is the number of months in the part of the basis period ending before the month in which the listing conversion occurs; and
(iii)
C is the total number of months in the basis period for the year of assessment;
(b)
the rebate against the tax payable for that year of assessment, pro-rated for the period after the listing conversion, must not exceed an amount determined by , where —(i)
A1 is —(A)
if the approved company has a market capitalisation of at least $1 billion on the date of occurrence of the listing conversion — $6 million; or
(B)
if the approved company has a market capitalisation of less than $1 billion on the date of occurrence of the listing conversion — $3 million; and
(ii)
B and C are the number of months mentioned in paragraph (a)(ii) and (iii), respectively.
(14) In this section, a listing conversion occurs when ordinary shares of an approved company which are listed by way of a primary listing on a stock exchange in Singapore, then becomes listed on that or another stock exchange in Singapore by way of a secondary listing, or vice versa.
Nomination of subsidiaries for rebate
(15) A company making an application under subsection (3) may, at any time before the application is approved —(a)
nominate for the approval of the Minister or authorised body, up to 3 of its eligible subsidiaries to which the rebate is to be made; and
(b)
where more than one eligible subsidiary is nominated, specify the order of priority in which the rebate is to be made to the nominees under subsection (26), which is to remain the same throughout the company’s incentive period.
(16) If less than 3 eligible subsidiaries are approved under subsection (15)(a), an approved company may at any time after its approval, nominate for the approval of the Minister or authorised body one or more of its other eligible subsidiaries to which the rebate is to be made, subject to the following:(a)
an approved company may not have more than 3 eligible subsidiaries approved as its nominees at any one time;
(b)
where more than one eligible subsidiary is nominated under this subsection, the approved company must in its application specify the order of priority in which the rebate is to be made to the nominees under subsection (26), which is to remain the same throughout the approved company’s incentive period;
(c)
in the order of priority mentioned in paragraph (b) —(i)
an eligible subsidiary that is approved under this subsection ranks below any other eligible subsidiary approved under subsection (15)(a); and
(ii)
an eligible subsidiary that is approved under this subsection ranks below any other eligible subsidiary whose effective date of approval is earlier than its date of approval.
(17) An approval of a nominee under subsection (15)(a) is effective from the first day of the month in which the listing date falls, or such other date as the Minister or authorised body may allow.
(18) An approval of a nominee under subsection (16) is effective from —(a)
the later of the following:(i)
the first day of the month in which the nomination is made;
(ii)
the first day of the month in which the nominee first becomes an eligible subsidiary of the approved company; or
(b)
such other date as the Minister or authorised body may allow.
(19) In this section, an “eligible subsidiary” of a company is a company that is wholly-owned (directly or indirectly) by the company and has a financial year that ends on the same day as that of the company.
(20) If any nominee approved by the Minister or authorised body (including one approved under subsection (22)) is in liquidation, ceases to carry on a trade or business in Singapore or ceases to exist at any time during the basis period for a year of assessment, then the approval of that nominee is treated as revoked as of the first day of that basis period in which the date of commencement of the liquidation or cessation falls.
(21) If any nominee approved by the Minister or authorised body (including one approved under subsection (22)) —(a)
ceases to be wholly-owned (directly or indirectly) by the approved company concerned; or
(b)
ceases to have a financial year that ends on the same day as that of the approved company,
at any time during the basis period for a year of assessment, then the approval of that nominee is treated as revoked as of the first day of that basis period.
(22) In a case mentioned in subsection (20) or (21), the approved company may, within such period as the Minister or authorised body may allow, apply to the Minister or authorised body for the approval of another of its eligible subsidiaries as a replacement nominee.
(23) An approval of the replacement nominee is effective from —(a)
the later of the following: (i)
the date the nominee being replaced is treated as revoked under subsection (20) or (21);
(ii)
the first day of the month in which the replacement nominee first becomes an eligible subsidiary of the approved company; or
(b)
such other date as the Minister or authorised body may allow,
and the replacement nominee assumes the position of the nominee being replaced in the order of priority specified under subsection (15)(b), or subsection (16)(b) read with subsection (16)(c), for the purpose of making the rebate.
(24) A company that is approved as a financial sector incentive company for the purposes of section 43J(1B), or its holding company, may not be nominated under subsection (15)(a), (16) or (22).
(25) The application under subsection (15), (16) or (22) must be accompanied by such information and documents as the Minister or authorised body may require.
(26) Where an approval is granted in respect of one or more nominees (including a replacement nominee) of an approved company, the rebate to be made to the approved company (as determined by subsections (10) to (13)) is instead to be made —(a)
first against the tax payable by the approved company in a year of assessment; and
(b)
then against the tax payable by those approved nominees in the same year of assessment in the order of priority specified under subsection (15)(b), or subsection (16)(b) read with subsection (16)(c),
until the applicable maximum amount of rebate under subsection (12)(a) or (b) or (13) (as the case may be) is reached; and subsections (10) and (11) apply with the necessary modifications to the making of the rebate against the tax payable by an approved nominee (including a replacement nominee) as they apply to the making of the rebate against the tax payable by the approved company.
Revocation of approval of approved company
(27) Section 105R applies to a failure to comply with a condition of approval (including the condition in subsection (8)) of an approved company under this section with the following modifications:(a)
a reference to a tax incentive is to a rebate under this section;
(b)
a reference to the application of a tax incentive to a person’s income is to the making of a rebate under this section against any tax payable by the approved company or its nominee;
(c)
the following subsections apply in place of section 105R(6):
“(6) Where —
(a)
a rebate has been made against the tax payable by the approved company or its nominee for a year of assessment;
(b)
the full or a part of the amount of the rebate would not have been so made if the company had no incentive period, or its incentive period had been reduced, owing to its not being an approved company under this section on any date in the basis period for that year of assessment; and
(c)
the approval is revoked under this section with effect from and including that date,
the full or part of the amount of rebate as mentioned in paragraph (b) (less any remission of tax under any provision in this Part (other than section 92)) is recoverable by the Comptroller as a debt due to the Government from the company or the nominee.
(6A) For the purpose of subsection (6) —
(a)
the amount recoverable is payable within one month after the service of a notice on the company or the nominee or such further time as the Comptroller may allow, subject to such terms and conditions as the Comptroller may impose, and in the manner stated in the notice; and
(b)
sections 57, 87(1) and (2), 89 and 90 apply to the collection and recovery by the Comptroller of that amount.”.
Miscellaneous
(28) A reference to a company in this section excludes a VCC.[Act 25 of 2025 wef 01/02/2025]
—(1) This section applies to a company the ordinary shares of which —(a)
are first listed on a stock exchange in Singapore on a date (called in this section the listing date) between 19 February 2025 and 31 December 2027 (both dates inclusive), by way of a primary listing or a secondary listing; and
(b)
are offered in conjunction with such listing.
(2) For the purposes of this section, the first listing of ordinary shares of a company on a stock exchange includes a relisting of ordinary shares of that company on that stock exchange, at any time after ordinary shares of that company have been delisted from that stock exchange.
(3) The company may apply to the Minister or an authorised body to be approved for the purposes of this section.
(4) An application under subsection (3) must be made within such period as the Minister or authorised body may allow, and must be accompanied by such information and documents as the Minister or authorised body may require.
(5) A company that is approved as a financial sector incentive company for the purposes of section 43J(1B), or its holding company, is not eligible to make an application under subsection (3).
(6) The Minister or authorised body may, subject to such conditions (including conditions subsequent) as the Minister or authorised body may impose, approve a company as an approved company for the purposes of this section.
(7) An approval under subsection (6) is for a single period of 5 years (called in this section the incentive period) starting from the first day of the month in which the listing date falls, and the earliest date on which an approval may take effect is 1 February 2025.
(8) It is a condition of approval of an approved company for its ordinary shares to remain listed on a stock exchange in Singapore throughout its incentive period, starting from its listing date.
(9) No approval under this section may be granted after 31 December 2027.
(10) The following is to be made to an approved company:(a)
where its ordinary shares are listed on a stock exchange in Singapore by way of a primary listing in the whole or part of the basis period for a year of assessment that is within its incentive period — a rebate computed in accordance with the following formula:
where —
(i)
A is —(A)
where the ordinary shares are so listed in the whole of the basis period within its incentive period — the number of months in that basis period;
(B)
where only a part of the basis period during which the ordinary shares are so listed falls within its incentive period — the number of months in that part;
(C)
where the ordinary shares are so listed in a part of the basis period within its incentive period before the occurrence of a listing conversion — the number of months in that part before the month in which the listing conversion occurs; or
(D)
where the ordinary shares are so listed in a part of the basis period within its incentive period after the occurrence of a listing conversion — the number of months in that part beginning with the month in which the listing conversion occurs;
(ii)
B is the total number of months in the basis period; and
(iii)
C is the tax payable by the approved company for that year of assessment as determined under subsection (11);
(b)
where its ordinary shares are listed on a stock exchange in Singapore by way of a secondary listing in the whole or part of the basis period for a year of assessment that is within its incentive period — a rebate computed in accordance with the following formula:
where —
(i)
A is —(A)
where the ordinary shares are so listed in the whole of the basis period within its incentive period — the number of months in that basis period;
(B)
where only a part of the basis period during which the ordinary shares are so listed falls within its incentive period — the number of months in that part;
(C)
where the ordinary shares are so listed in a part of the basis period within its incentive period before the occurrence of a listing conversion — the number of months in that part before the month in which the listing conversion occurs; or
(D)
where the ordinary shares are so listed in a part of the basis period within its incentive period after the occurrence of a listing conversion — the number of months in that part beginning with the month in which the listing conversion occurs;
(ii)
B is the total number of months in the basis period; and
(iii)
C is the tax payable by the approved company for that year of assessment as determined under subsection (11).
(11) In subsection (10)(a)(iii) and (b)(iii), the tax payable by the approved company for a year of assessment is the amount of tax levied on the chargeable income of the approved company under Part 11 for that year of assessment (excluding any tax levied under section 43(3), (3A), (3B) and (3C)) —(a)
before making any set-off under Part 13;
(b)
before making any remission of the tax under any other provision of this Part; and
(c)
after making any deduction of tax credit under Part 14.
(12) The rebate to be made to an approved company against the tax payable for each year of assessment must not exceed —(a)
if the approved company has a market capitalisation of at least $1 billion on the listing date — $6 million; or
(b)
if the approved company has a market capitalisation of less than $1 billion on the listing date — $3 million.
(13) If a listing conversion occurs in the basis period for a year of assessment, then the maximum amount of rebate to be made to the approved company against the tax payable for that year of assessment is to be computed as follows:(a)
the rebate against the tax payable for that year of assessment, pro-rated for the period before the listing conversion, must not exceed an amount determined by , where —(i)
A is the amount mentioned in subsection (12)(a) or (b) (whichever is applicable);
(ii)
B is the number of months in the part of the basis period ending before the month in which the listing conversion occurs; and
(iii)
C is the total number of months in the basis period for the year of assessment;
(b)
the rebate against the tax payable for that year of assessment, pro-rated for the period after the listing conversion, must not exceed an amount determined by , where —(i)
A1 is —(A)
if the approved company has a market capitalisation of at least $1 billion on the date of occurrence of the listing conversion — $6 million; or
(B)
if the approved company has a market capitalisation of less than $1 billion on the date of occurrence of the listing conversion — $3 million; and
(ii)
B and C are the number of months mentioned in paragraph (a)(ii) and (iii), respectively.
(14) In this section, a listing conversion occurs when ordinary shares of an approved company which are listed by way of a primary listing on a stock exchange in Singapore, then becomes listed on that or another stock exchange in Singapore by way of a secondary listing, or vice versa.
(15) A company making an application under subsection (3) may, at any time before the application is approved —(a)
nominate for the approval of the Minister or authorised body, up to 3 of its eligible subsidiaries to which the rebate is to be made; and
(b)
where more than one eligible subsidiary is nominated, specify the order of priority in which the rebate is to be made to the nominees under subsection (26), which is to remain the same throughout the company’s incentive period.
(16) If less than 3 eligible subsidiaries are approved under subsection (15)(a), an approved company may at any time after its approval, nominate for the approval of the Minister or authorised body one or more of its other eligible subsidiaries to which the rebate is to be made, subject to the following:(a)
an approved company may not have more than 3 eligible subsidiaries approved as its nominees at any one time;
(b)
where more than one eligible subsidiary is nominated under this subsection, the approved company must in its application specify the order of priority in which the rebate is to be made to the nominees under subsection (26), which is to remain the same throughout the approved company’s incentive period;
(c)
in the order of priority mentioned in paragraph (b) —(i)
an eligible subsidiary that is approved under this subsection ranks below any other eligible subsidiary approved under subsection (15)(a); and
(ii)
an eligible subsidiary that is approved under this subsection ranks below any other eligible subsidiary whose effective date of approval is earlier than its date of approval.
(17) An approval of a nominee under subsection (15)(a) is effective from the first day of the month in which the listing date falls, or such other date as the Minister or authorised body may allow.
(18) An approval of a nominee under subsection (16) is effective from —(a)
the later of the following:(i)
the first day of the month in which the nomination is made;
(ii)
the first day of the month in which the nominee first becomes an eligible subsidiary of the approved company; or
(b)
such other date as the Minister or authorised body may allow.
(19) In this section, an “eligible subsidiary” of a company is a company that is wholly-owned (directly or indirectly) by the company and has a financial year that ends on the same day as that of the company.
(20) If any nominee approved by the Minister or authorised body (including one approved under subsection (22)) is in liquidation, ceases to carry on a trade or business in Singapore or ceases to exist at any time during the basis period for a year of assessment, then the approval of that nominee is treated as revoked as of the first day of that basis period in which the date of commencement of the liquidation or cessation falls.
(21) If any nominee approved by the Minister or authorised body (including one approved under subsection (22)) —(a)
ceases to be wholly-owned (directly or indirectly) by the approved company concerned; or
(b)
ceases to have a financial year that ends on the same day as that of the approved company,
at any time during the basis period for a year of assessment, then the approval of that nominee is treated as revoked as of the first day of that basis period.
(22) In a case mentioned in subsection (20) or (21), the approved company may, within such period as the Minister or authorised body may allow, apply to the Minister or authorised body for the approval of another of its eligible subsidiaries as a replacement nominee.
(23) An approval of the replacement nominee is effective from —(a)
the later of the following: (i)
the date the nominee being replaced is treated as revoked under subsection (20) or (21);
(ii)
the first day of the month in which the replacement nominee first becomes an eligible subsidiary of the approved company; or
(b)
such other date as the Minister or authorised body may allow,
and the replacement nominee assumes the position of the nominee being replaced in the order of priority specified under subsection (15)(b), or subsection (16)(b) read with subsection (16)(c), for the purpose of making the rebate.
(24) A company that is approved as a financial sector incentive company for the purposes of section 43J(1B), or its holding company, may not be nominated under subsection (15)(a), (16) or (22).
(25) The application under subsection (15), (16) or (22) must be accompanied by such information and documents as the Minister or authorised body may require.
(26) Where an approval is granted in respect of one or more nominees (including a replacement nominee) of an approved company, the rebate to be made to the approved company (as determined by subsections (10) to (13)) is instead to be made —(a)
first against the tax payable by the approved company in a year of assessment; and
(b)
then against the tax payable by those approved nominees in the same year of assessment in the order of priority specified under subsection (15)(b), or subsection (16)(b) read with subsection (16)(c),
until the applicable maximum amount of rebate under subsection (12)(a) or (b) or (13) (as the case may be) is reached; and subsections (10) and (11) apply with the necessary modifications to the making of the rebate against the tax payable by an approved nominee (including a replacement nominee) as they apply to the making of the rebate against the tax payable by the approved company.
(27) Section 105R applies to a failure to comply with a condition of approval (including the condition in subsection (8)) of an approved company under this section with the following modifications:(a)
a reference to a tax incentive is to a rebate under this section;
(b)
a reference to the application of a tax incentive to a person’s income is to the making of a rebate under this section against any tax payable by the approved company or its nominee;
(c)
the following subsections apply in place of section 105R(6):
“(6) Where —
(a)
a rebate has been made against the tax payable by the approved company or its nominee for a year of assessment;
(b)
the full or a part of the amount of the rebate would not have been so made if the company had no incentive period, or its incentive period had been reduced, owing to its not being an approved company under this section on any date in the basis period for that year of assessment; and
(c)
the approval is revoked under this section with effect from and including that date,
the full or part of the amount of rebate as mentioned in paragraph (b) (less any remission of tax under any provision in this Part (other than section 92)) is recoverable by the Comptroller as a debt due to the Government from the company or the nominee.
(6A) For the purpose of subsection (6) —
(a)
the amount recoverable is payable within one month after the service of a notice on the company or the nominee or such further time as the Comptroller may allow, subject to such terms and conditions as the Comptroller may impose, and in the manner stated in the notice; and
(b)
sections 57, 87(1) and (2), 89 and 90 apply to the collection and recovery by the Comptroller of that amount.”.
(28) A reference to a company in this section excludes a VCC.[Act 25 of 2025 wef 01/02/2025]
Remission of tax for companies for year of assessment 2025 and cash grant for companies
92L.—(1) Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2025 by the company of an amount equal to the lower of the following:(a)
50% of the tax payable for that year of assessment (excluding any tax levied under section 43(3), (3A), (3B) and (3C)), less the cash grant of $2,000 made to the company under subsection (3), where applicable;
(b)
$40,000, less the cash grant of $2,000 made to the company under subsection (3), where applicable.
(2) However, where 50% of the tax payable under subsection (1)(a) is less than the cash grant of $2,000, the amount in subsection (1)(a) is nil.
(3) Subject to subsection (4), where a company has made a CPF contribution in respect of at least one local employee in the calendar year 2024 in accordance with regulation 2(1) of the Central Provident Fund Regulations (called in this section the time requirement), there is to be made to the company a cash grant of $2,000.
(4) Unless the Comptroller otherwise permits, no cash grant may be made to a company (X) if, at the time of disbursement —(a)
X is not carrying on a trade or business (including the activity of holding any investments);
(b)
X is in liquidation;
(c)
X is under receivership in respect of all of its properties; or
(d)
X has ceased to exist.
(5) The Comptroller may waive the time requirement under subsection (3) if the Comptroller is satisfied that it is just and equitable to do so.
(6) The cash grant under subsection (3) is exempt from tax in the hands of the company.
(7) For the purpose of subsection (3) —“central hirer” and “central hiring arrangement” have the meanings given by section 14ZG(5);
“CPF contribution” means a contribution to the Central Provident Fund that is obligatory under section 7(1) of the Central Provident Fund Act 1953;
“employee”, in relation to a company, means —(a)
an individual who is an employee of the company for any period in the calendar year 2024 and is on the payroll of the company for that period;
(b)
an individual —(i)
who is engaged by the central hirer of a central hiring arrangement for a group of related parties that includes the company;
(ii)
who is deployed to work solely for the company for any period in the calendar year 2024;
(iii)
who is on the payroll of the central hirer or the company for that period; and
(iv)
whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company; or
(c)
an individual —(i)
who, being an employee of another person that is a related party of the company (called in this subsection and subsection (8) the employer), is seconded to a position in the company under a bona fide commercial arrangement to work solely for the company for any period in the calendar year 2024;
(ii)
who is on the payroll of the employer or the company for that period; and
(iii)
whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company,
but excludes any individual who is a shareholder and also a director of the company;
“local employee” means a Singapore citizen or Singapore permanent resident who is an employee of the company.
(8) For the purpose of determining whether the individual mentioned in paragraph (b) or (c) of the definition of “employee” in subsection (7) is also an employee of the central hirer or the employer by virtue of paragraph (a) of that definition, the period mentioned in paragraph (b) or (c) (as the case may be) is to be disregarded for the purpose of paragraph (a) of that definition.[Act 25 of 2025 wef 08/12/2025]
—(1) Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2025 by the company of an amount equal to the lower of the following:(a)
50% of the tax payable for that year of assessment (excluding any tax levied under section 43(3), (3A), (3B) and (3C)), less the cash grant of $2,000 made to the company under subsection (3), where applicable;
(b)
$40,000, less the cash grant of $2,000 made to the company under subsection (3), where applicable.
(2) However, where 50% of the tax payable under subsection (1)(a) is less than the cash grant of $2,000, the amount in subsection (1)(a) is nil.
(3) Subject to subsection (4), where a company has made a CPF contribution in respect of at least one local employee in the calendar year 2024 in accordance with regulation 2(1) of the Central Provident Fund Regulations (called in this section the time requirement), there is to be made to the company a cash grant of $2,000.
(4) Unless the Comptroller otherwise permits, no cash grant may be made to a company (X) if, at the time of disbursement —(a)
X is not carrying on a trade or business (including the activity of holding any investments);
(b)
X is in liquidation;
(c)
X is under receivership in respect of all of its properties; or
(d)
X has ceased to exist.
(5) The Comptroller may waive the time requirement under subsection (3) if the Comptroller is satisfied that it is just and equitable to do so.
(6) The cash grant under subsection (3) is exempt from tax in the hands of the company.
(7) For the purpose of subsection (3) —“central hirer” and “central hiring arrangement” have the meanings given by section 14ZG(5);
“CPF contribution” means a contribution to the Central Provident Fund that is obligatory under section 7(1) of the Central Provident Fund Act 1953;
“employee”, in relation to a company, means —(a)
an individual who is an employee of the company for any period in the calendar year 2024 and is on the payroll of the company for that period;
(b)
an individual —(i)
who is engaged by the central hirer of a central hiring arrangement for a group of related parties that includes the company;
(ii)
who is deployed to work solely for the company for any period in the calendar year 2024;
(iii)
who is on the payroll of the central hirer or the company for that period; and
(iv)
whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company; or
(c)
an individual —(i)
who, being an employee of another person that is a related party of the company (called in this subsection and subsection (8) the employer), is seconded to a position in the company under a bona fide commercial arrangement to work solely for the company for any period in the calendar year 2024;
(ii)
who is on the payroll of the employer or the company for that period; and
(iii)
whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company,
but excludes any individual who is a shareholder and also a director of the company;
“local employee” means a Singapore citizen or Singapore permanent resident who is an employee of the company.
(8) For the purpose of determining whether the individual mentioned in paragraph (b) or (c) of the definition of “employee” in subsection (7) is also an employee of the central hirer or the employer by virtue of paragraph (a) of that definition, the period mentioned in paragraph (b) or (c) (as the case may be) is to be disregarded for the purpose of paragraph (a) of that definition.[Act 25 of 2025 wef 08/12/2025]
Repayment of tax
93.—(1) If it is proved to the Comptroller’s satisfaction that any person for any year of assessment has paid tax, by deduction or otherwise, in excess of the amount payable under the provisions of this Act, such person is entitled to have the amount so paid in excess refunded.(2) Every claim for repayment under this section must be made within 6 years (if the year of assessment to which the claim relates is 2007 or a preceding year of assessment) or 4 years (if the year of assessment to which the claim relates is 2008 or a subsequent year of assessment) from the end of the year of assessment to which the claim relates.
(3) This section does not operate to extend any time limit for appeal or validate any objection or appeal which is otherwise invalid or authorise the revision of any assessment or other matter which has become final and conclusive.
(4) [Deleted by Act 19 of 2013]
(5) Where through death, incapacity, bankruptcy, liquidation or other cause a person who would, but for such cause, have been entitled to make a claim under subsection (1) is unable to do so, the person’s executor, trustee or receiver (as the case may be) is entitled to have refunded to the executor, trustee or receiver for the benefit of such person or the person’s estate any tax paid in excess within the meaning of subsection (1).
(6) The Comptroller must certify any amount repayable under this section and must cause repayment to be made immediately.
(7) Where an order or decision by the Board of Review or by any court gives rise to any claim for a refund of tax, the Comptroller may, where the Comptroller has given written notice of the Comptroller’s intention to appeal against such order or decision, withhold the refund until such time as the appeal is finally determined.
(8) Where a refund is withheld under subsection (7), the Comptroller must pay interest at the rate mentioned in subsection (9) with effect from the date of the order or decision appealed against on the amount of refund ultimately determined to be due as a result of any appeal.[2/2016]
(9) In subsection (8), the rate of interest is —(a)
for any part of the period for which interest is payable (called in this subsection the interest period) up to and including 30 June 2016, 5% per annum;
(b)
for any part of the interest period that is later but falling before the publication date, the average of the prime lending rates for such months in the previous year as are prescribed by rules made under section 7;
(c)
for any part of the interest period falling on or after the publication date but within the period between 1 January and 31 March (both dates inclusive) of any year before 2025, the prime lending rate for the year that is 2 years before that year; [Act 30 of 2023 wef 30/10/2023]
(d)
for any part of the interest period falling on or after the publication date but within the period between 1 April and 31 December (both dates inclusive) of any year before 2024, the prime lending rate for the previous year; or[Act 30 of 2023 wef 30/10/2023]
(e)
for any part of the interest period falling on or after 1 April 2024, the rate as prescribed by rules made under section 7.[Act 30 of 2023 wef 30/10/2023]
[34/2016]
(10) In subsection (9), “publication date” means 29 December 2016.[34/2016]
(11) In subsection (9)(c) and (d), the prime lending rate for any year is the average of the prime lending rates for the months of October, November and December of that year, or such other months prescribed by rules made under section 7 in their place, of such financial institution or financial institutions in Singapore as the Minister may determine, rounded to the nearest 0.5%, or another percentage prescribed by rules made under that section in its place.[34/2016]
(12) Rules made under section 7 for the purpose of subsection (9)(e) may prescribe different rates for different parts of the interest period.[Act 30 of 2023 wef 30/10/2023]
—(1) If it is proved to the Comptroller’s satisfaction that any person for any year of assessment has paid tax, by deduction or otherwise, in excess of the amount payable under the provisions of this Act, such person is entitled to have the amount so paid in excess refunded.
(2) Every claim for repayment under this section must be made within 6 years (if the year of assessment to which the claim relates is 2007 or a preceding year of assessment) or 4 years (if the year of assessment to which the claim relates is 2008 or a subsequent year of assessment) from the end of the year of assessment to which the claim relates.
(3) This section does not operate to extend any time limit for appeal or validate any objection or appeal which is otherwise invalid or authorise the revision of any assessment or other matter which has become final and conclusive.
(4) [Deleted by Act 19 of 2013]
(5) Where through death, incapacity, bankruptcy, liquidation or other cause a person who would, but for such cause, have been entitled to make a claim under subsection (1) is unable to do so, the person’s executor, trustee or receiver (as the case may be) is entitled to have refunded to the executor, trustee or receiver for the benefit of such person or the person’s estate any tax paid in excess within the meaning of subsection (1).
(6) The Comptroller must certify any amount repayable under this section and must cause repayment to be made immediately.
(7) Where an order or decision by the Board of Review or by any court gives rise to any claim for a refund of tax, the Comptroller may, where the Comptroller has given written notice of the Comptroller’s intention to appeal against such order or decision, withhold the refund until such time as the appeal is finally determined.
(8) Where a refund is withheld under subsection (7), the Comptroller must pay interest at the rate mentioned in subsection (9) with effect from the date of the order or decision appealed against on the amount of refund ultimately determined to be due as a result of any appeal.[2/2016]
(9) In subsection (8), the rate of interest is —(a)
for any part of the period for which interest is payable (called in this subsection the interest period) up to and including 30 June 2016, 5% per annum;
(b)
for any part of the interest period that is later but falling before the publication date, the average of the prime lending rates for such months in the previous year as are prescribed by rules made under section 7;
(c)
for any part of the interest period falling on or after the publication date but within the period between 1 January and 31 March (both dates inclusive) of any year before 2025, the prime lending rate for the year that is 2 years before that year; [Act 30 of 2023 wef 30/10/2023]
(d)
for any part of the interest period falling on or after the publication date but within the period between 1 April and 31 December (both dates inclusive) of any year before 2024, the prime lending rate for the previous year; or[Act 30 of 2023 wef 30/10/2023]
(e)
for any part of the interest period falling on or after 1 April 2024, the rate as prescribed by rules made under section 7.[Act 30 of 2023 wef 30/10/2023]
[34/2016]
(10) In subsection (9), “publication date” means 29 December 2016.[34/2016]
(11) In subsection (9)(c) and (d), the prime lending rate for any year is the average of the prime lending rates for the months of October, November and December of that year, or such other months prescribed by rules made under section 7 in their place, of such financial institution or financial institutions in Singapore as the Minister may determine, rounded to the nearest 0.5%, or another percentage prescribed by rules made under that section in its place.[34/2016]
(12) Rules made under section 7 for the purpose of subsection (9)(e) may prescribe different rates for different parts of the interest period.[Act 30 of 2023 wef 30/10/2023]
Relief in respect of error or mistake
93A.—(1) If any person alleges that for any year of assessment —(a)
an assessment is excessive; or
(b)
any unabsorbed loss, allowance or donation that may be carried forward ought to be of a higher amount than that set out in an assessment,
by reason of some error or mistake —
(c)
in the return or statement made by the person for the purposes of the assessment; or
(d)
where the person is exempted from liability to furnish a return under section 62(2), in the notice of assessment served on the person,
the person may, at any time not later than 6 years (if the year of assessment within which the assessment was made is 2007 or a preceding year of assessment) or 4 years (if the year of assessment within which the assessment is made is 2008 or a subsequent year of assessment) after the end of the year of assessment within which the assessment was made, make an application in writing to the Comptroller for relief.
(1A) An application by a person on the basis of an error or a mistake, for the year of assessment 2019 or any subsequent year of assessment, in the amount of any income, expense, outgoing or loss in connection with any transaction between the person and a related party of the person, must be supported by transfer pricing documentation for that transaction that satisfies section 34F(5).[39/2017]
[Act 33 of 2022 wef 04/11/2022]
(1B) To avoid doubt, subsection (1A) applies whether or not the person is a company, firm, partner of a partnership or trustee of a trust to which section 34F applies.[39/2017]
(2) On receiving the application, the Comptroller must inquire into the matter and must, subject to this section, give, by way of repayment of tax or an amendment to the assessment, such relief in respect of the error or mistake as appears to the Comptroller to be reasonable and just.
(3) No relief by way of repayment of tax may be given under this section in respect of an error or a mistake as to the basis on which the liability of the applicant ought to have been computed when the return or statement was in fact made on the basis of or in accordance with the practice of the Comptroller generally prevailing at the time when the return or statement was made.
(3A) No amendment may be made to the assessment under this section when the return or statement was in fact made on the basis of or in accordance with the practice of the Comptroller generally prevailing at the time when the return or statement was made.
(4) In determining any application under this section, the Comptroller must have regard to all the relevant circumstances of the case, and in particular must consider whether the granting of relief would result in the exclusion from charge to tax of income of the applicant, and for this purpose the Comptroller may take into consideration the liability of the applicant and assessments made upon the applicant in respect of other years.
(5) Section 79 applies in respect of an appeal against a determination of the Comptroller under this section except that no such appeal may be entertained until the sum of $250 has been deposited with the secretary to the Board of Review.
(6) The sum mentioned in subsection (5) must be refunded in the event of the appeal being allowed.
(7) The Board of Review may, if in its opinion the appeal was vexatious or frivolous, order that the whole or any part of the aforesaid sum be forfeited and awarded to the Comptroller as costs.
—(1) If any person alleges that for any year of assessment —(a)
an assessment is excessive; or
(b)
any unabsorbed loss, allowance or donation that may be carried forward ought to be of a higher amount than that set out in an assessment,
by reason of some error or mistake —
(c)
in the return or statement made by the person for the purposes of the assessment; or
(d)
where the person is exempted from liability to furnish a return under section 62(2), in the notice of assessment served on the person,
the person may, at any time not later than 6 years (if the year of assessment within which the assessment was made is 2007 or a preceding year of assessment) or 4 years (if the year of assessment within which the assessment is made is 2008 or a subsequent year of assessment) after the end of the year of assessment within which the assessment was made, make an application in writing to the Comptroller for relief.
(1A) An application by a person on the basis of an error or a mistake, for the year of assessment 2019 or any subsequent year of assessment, in the amount of any income, expense, outgoing or loss in connection with any transaction between the person and a related party of the person, must be supported by transfer pricing documentation for that transaction that satisfies section 34F(5).[39/2017]
[Act 33 of 2022 wef 04/11/2022]
(1B) To avoid doubt, subsection (1A) applies whether or not the person is a company, firm, partner of a partnership or trustee of a trust to which section 34F applies.[39/2017]
(2) On receiving the application, the Comptroller must inquire into the matter and must, subject to this section, give, by way of repayment of tax or an amendment to the assessment, such relief in respect of the error or mistake as appears to the Comptroller to be reasonable and just.
(3) No relief by way of repayment of tax may be given under this section in respect of an error or a mistake as to the basis on which the liability of the applicant ought to have been computed when the return or statement was in fact made on the basis of or in accordance with the practice of the Comptroller generally prevailing at the time when the return or statement was made.
(3A) No amendment may be made to the assessment under this section when the return or statement was in fact made on the basis of or in accordance with the practice of the Comptroller generally prevailing at the time when the return or statement was made.
(4) In determining any application under this section, the Comptroller must have regard to all the relevant circumstances of the case, and in particular must consider whether the granting of relief would result in the exclusion from charge to tax of income of the applicant, and for this purpose the Comptroller may take into consideration the liability of the applicant and assessments made upon the applicant in respect of other years.
(5) Section 79 applies in respect of an appeal against a determination of the Comptroller under this section except that no such appeal may be entertained until the sum of $250 has been deposited with the secretary to the Board of Review.
(6) The sum mentioned in subsection (5) must be refunded in the event of the appeal being allowed.
(7) The Board of Review may, if in its opinion the appeal was vexatious or frivolous, order that the whole or any part of the aforesaid sum be forfeited and awarded to the Comptroller as costs.
Modification of section 93 for repayment of tax for training allowance under Workfare Training Support scheme
93AA.—(1) Section 93 (Repayment of tax) applies to enable a person who had paid tax in respect of any payment mentioned in section 13(1)(zpa) that ought not to have been paid because of the backdating of the date of commencement of section 5(1)(a) of the Finance (Income Taxes) Act 2025.(2) In the application of section 93 under subsection (1), section 93(2) is replaced with the following:
“(2) A claim for repayment must be made to the Comptroller by 31 December 2029.”.
[Act 25 of 2025 wef 08/12/2025]
—(1) Section 93 (Repayment of tax) applies to enable a person who had paid tax in respect of any payment mentioned in section 13(1)(zpa) that ought not to have been paid because of the backdating of the date of commencement of section 5(1)(a) of the Finance (Income Taxes) Act 2025.
(2) In the application of section 93 under subsection (1), section 93(2) is replaced with the following:
“(2) A claim for repayment must be made to the Comptroller by 31 December 2029.”.
[Act 25 of 2025 wef 08/12/2025]
Refundable investment credits
93B.—(1) This section provides for tax credits to be given for qualifying expenditure incurred by companies, to be offset against any income tax levied on, and any penalty, surcharge or interest related to income tax and due from, the companies, and for unutilised tax credits to be paid to the companies.Definitions
(2) In this section —“awardee company” means a company given a letter of award under subsection (4);
“claim period”, in relation to a company given a letter of award, means the period mentioned in subsection (5)(h) that is specified in the letter of award;
“date of amalgamation” means the date shown on the notice of amalgamation under section 215F of the Companies Act 1967;
“DTT” and “MTT” have the meanings given by section 2(1) of the MMT Act, and includes any penalty, surcharge or interest payable to the Comptroller under that Act;
“due tax” has the meaning given by subsection (24);
“letter of award” means a letter of award given under subsection (4);
“letter of confirmation” means a letter of confirmation given under subsection (17);
“MMT Act” means the Multinational Enterprise (Minimum Tax) Act 2024;
“payment date” has the meaning given by subsection (23);
“payout date”, in relation to a company given a letter of confirmation, means the date mentioned in subsection (20) that is specified in the letter;
“qualifying activity” means any activity prescribed as a qualifying activity by regulations made under subsection (51);
“qualifying expenditure” means any expenditure specified in the letter of award concerned, incurred in carrying out the qualifying activity specified in the letter;
“qualifying period”, in relation to a company given a letter of award, means the period mentioned in subsection (5)(c) that is specified in the letter;
“recoverable amount” has the meaning given by subsection (38) or (39), as the case may be;
“RIC” or “refundable investment credit” means a tax credit given to an awardee company under this section for qualifying expenditure incurred in carrying out a qualifying activity;
“RIC account” means an account kept by that name under subsection (22) or (45);
“tax” includes any penalty, surcharge or interest payable to the Comptroller under this Act, other than an amount payable to the Comptroller as withholding tax;
“unutilised RICs” means RICs given to an awardee company that have not been —(a)
used to offset any tax, DTT or MTT that is levied on or due from the awardee company, or another company in the same group as the awardee company under regulations made for the purpose of subsection (46);
(b)
debited from the RIC account of the company under subsection (40)(a) (including that provision as applied by subsections (14A) and (20B)); or[Act 25 of 2025 wef 08/12/2025]
(c)
paid to the awardee company.
Application for approval to be given RICs
(3) A company engaged in, or which desires to engage in, a qualifying activity may apply to the Minister or an authorised body (called in this section the approving authority), in the form and manner determined by the approving authority, for approval to be given RICs for qualifying expenditure incurred in carrying out that activity.
(4) The approving authority may, if the approving authority considers it expedient in the public interest to do so, approve the application and issue to the company a letter of award.
(5) Each letter of award must state —(a)
the qualifying activity for which the approval is given;
(b)
the type or types of qualifying expenditure in carrying out the qualifying activity for which RICs may be given;
(c)
the period (called in this section the qualifying period) in which the qualifying expenditure is to be incurred, which must not exceed 10 years;
(d)
the maximum amount of RICs to be given for all the qualifying expenditure and the maximum amount of RICs to be given for each type of qualifying expenditure, as determined by the approving authority;
(e)
the rate or rates used in computing the amount of RICs;
(f)
the conditions to be complied with for the company to be given or to retain an amount of RICs;
(g)
any other condition (called in this section an additional condition) that must be complied with for a specified part of the first maximum amount of RICs mentioned in paragraph (d) to be given;
(h)
the period (called in this section the claim period) within which the company may claim for an amount of RICs; and
(i)
the last day by which unutilised RICs are to be paid to the company, which must not be later than 4 years starting from the date that the company makes the application under subsection (15) pursuant to which those RICs were given.[Act 25 of 2025 wef 08/12/2025]
(6) For the purposes of subsection (5)(b), (c), (f) and (g), the approving authority may specify different qualifying expenditures, different qualifying periods, and different conditions for different types of qualifying activities.
(7) For the purpose of subsection (5)(c), the approving authority may specify a qualifying period that begins from a date before the date of commencement of section 30 of the Income Tax (Amendment) Act 2024, but not earlier than 1 July 2024.
(8) For the purpose of subsection (5)(e), the regulations may specify one or more rates for computing the amount of RICs for each type of qualifying expenditure, and prescribe the factors which the approving authority must consider in determining the rate to specify for that type of qualifying expenditure in each letter of award.
(9) For the purpose of this section, a reference to RIC for each type of qualifying expenditure is to the RICs computed using the rate specified for that type of qualifying expenditure in the letter of award.
(10) Where the approving authority approves an application by a company for 2 or more qualifying activities, the approving authority may issue a single letter of award for those activities if the approving authority is satisfied that the company is engaged in or desires to engage in all those activities as part of the same project.
(11) No approval may be given after 31 December 2029.
Amendment of approval
(12) The approving authority may, on the application of an awardee company, amend any of the following matters in the letter of award:(a)
the qualifying activity;
(b)
the type or types of qualifying expenditure for carrying out the qualifying activity for which RICs may be given;
(c)
the commencement or end date of the qualifying period, except that the total period after the amendment must not exceed 10 years;
(d)
the maximum amount of RICs to be given for all the qualifying expenditure or the maximum amount of RICs to be given for each type of qualifying expenditure;
(e)
any rate used in computing the amount of RICs;
(f)
any condition (including any additional condition);
(g)
any claim period;
(h)
the last day by which any unutilised RICs must be paid to the company, which must not be later than 4 years starting from the date that the company makes the application under subsection (15) pursuant to which those RICs were given.[Act 25 of 2025 wef 08/12/2025]
(13) Subsection (12) does not prevent the approving authority from making any amendment to correct any error in the letter of award.
(14) If the approving authority approves an application to amend a matter in subsection (12), a reference in this section to that matter in relation to the company is to that matter as so amended.
(14A) Subsections (38)(b), (40), (41) and (42) apply with the necessary modifications to an amendment of a letter of award under subsection (13) or (14) as they apply to an amendment of a letter of award under subsection (35)(a).[Act 25 of 2025 wef 08/12/2025]
Giving of RICs
(15) After an awardee company has incurred in its qualifying period an amount of qualifying expenditure specified in its letter of award in carrying out the qualifying activity specified in the letter, the awardee company may apply to the approving authority for an amount of RICs stated in the letter for that amount and type of the expenditure.
(16) The application must be made within the claim period or such extended period as the approving authority may allow, and must be accompanied by such information and documents as the approving authority may require.
(17) If, the approving authority is satisfied that —(a)
the awardee company has incurred any qualifying expenditure; and
(b)
the awardee company has complied with every condition that is to be complied with by a date that is on or before the date of the application, or it is just and reasonable, having regard to any representation of the company and all relevant circumstances of the case, to treat every such condition as having been complied with,
the approving authority must, by a letter of confirmation to the awardee company, give to the company an amount of RICs for the type or types of qualifying expenditure to which the qualifying expenditure in paragraph (a) belongs, as determined by subsections (18) and (19).
(18) Subject to subsection (19), the amount of RICs for each type of qualifying expenditure is the lesser of —(a)
the maximum amount of RICs specified in the letter of award less any RICs already given for that type of qualifying expenditure in previous letters of confirmation pursuant to the same letter of award; and
(b)
an amount determined by the formula
where —
(i)
A is the amount of the qualifying expenditure incurred and not claimed in previous letters of confirmation pursuant to the same letter of award; and
(ii)
B is the rate specified in the letter of award that applies to that type of qualifying expenditure.
(19) The amount of RICs given by a letter of confirmation must not exceed the maximum amount of RICs that may be given for all qualifying expenditure as specified in the letter of award, less —(a)
any RICs given in previous letters of confirmation pursuant to the same letter of award; and
(b)
if any additional condition has yet to be complied with, the specified part of the maximum amount of RICs that may only be given upon compliance.
(20) The letter of confirmation must state the payout date for unutilised RICs, which must not be later than the last day specified in the letter of award under subsection (5)(i) as amended (if applicable) under subsection (12).
(20A) The approving authority may, in any prescribed circumstances, on the application by an awardee company or on its own initiative, amend any matter stated in a letter of confirmation given to the awardee company.[Act 25 of 2025 wef 08/12/2025]
(20B) Where an amendment is made to a letter of confirmation under subsection (20A) —(a)
a reference in this section to that matter in relation to the awardee company is to that matter as so amended; and
(b)
subsections (38)(b), (40), (41) and (42) apply with the necessary modifications to the amendment as they apply to an amendment of a letter of award under subsection (35)(a), and for this purpose, a reference to the letter of award in subsection (38)(b) is to the letter of confirmation.[Act 25 of 2025 wef 08/12/2025]
(21) To avoid doubt, the approving authority may issue one or more letters of confirmation to the awardee company in respect of each letter of award issued to the company.
(22) The RICs given to the awardee company must be credited to an account called the “RIC account” for the purposes of this section.
Election for RICs to be paid
(23) Regulations may be made under subsection (51) —(a)
to allow, in any prescribed circumstances, an awardee company to make an election for any amount of RICs given to it to be paid to it in a specified manner and on a date specified by the approving authority (called in this section the payment date), which must not be later than 4 years starting from the date that the company makes the application under subsection (15) pursuant to which those RICs were given; and [Act 25 of 2025 wef 08/12/2025]
(b)
to provide for the revocation of such election and the circumstances under which such election is treated as revoked, and other matters relating to such election.[Act 25 of 2025 wef 08/12/2025]
Use of RICs to offset due taxes
(24) Subsections (25) to (29) apply where —(a)
there are RICs in an RIC account of an awardee company;
(b)
either —(i)
an amount of tax is levied on or due from the company under this Act; or
(ii)
an amount of DTT or MTT is levied on or due from the company under the MMT Act,
(each called in this section due tax); and
(c)
the company has not made an election under regulations made under subsection (23) for those RICs to be paid to the company.
(25) Subject to the regulations made under subsection (51), the Comptroller must —(a)
offset an amount of the due tax against the credit in the RIC account that is the lower of the due tax and the credit in the RIC account; and
(b)
debit the company’s RIC account with such amount.
(26) When the Comptroller offsets an amount of due tax against the RIC account of an awardee company under subsection (25), that amount of due tax is treated as paid, and the Comptroller must give notice of such payment to the awardee company.
(27) If —(a)
an awardee company has more than one due tax; and
(b)
the credit in its RIC account is less than the sum of the amounts of those due taxes,
the Comptroller may determine in a manner he or she considers reasonable —
(c)
the due tax or due taxes to be offset under subsection (25); and
(d)
if the credit is sufficient to offset more than one due tax, the order and amount by which the due taxes are to be offset under that subsection.
(28) RICs in an RIC account that are given on an earlier date are to be fully applied to offset due taxes under subsection (25) before RICs in the same account that are given on a later date.
(29) RICs remaining in an RIC account may not be applied to offset due taxes under subsection (25) after the prescribed day before the payout date.
Payment of RICs
(30) Subsections (31) and (32) apply where —(a)
on the prescribed day before the payout date, there are RICs remaining in an RIC account of an awardee company; or
(b)
an awardee company has made an election under regulations made for the purpose of subsection (23) for any RICs given to it to be paid to it by the payment date, and the prescribed day before the payment date has arrived.
(31) The Comptroller is to make a monetary payment equivalent to the amount of those RICs to the awardee company on or before the payout date or payment date, to the extent that they have not been —(a)
revoked, or treated as revoked under the regulations; or
(b)
debited under subsection (40)(a) (including that provision as applied by subsections (14A) and (20B)).[Act 25 of 2025 wef 08/12/2025]
(32) Upon the making of the payment, those RICs are to be debited from the RIC account of the awardee company.
Where awardee company has not complied with Act or condition
(33) Subsections (34) to (42) apply where the approving authority is satisfied that an awardee company —(a)
has not complied with a provision of this Act or regulations made under subsection (51);
(b)
has not complied with a condition (including any additional condition) in its letter of award by the date it is to be complied with; or
(c)
in an application to the approving authority, provided any information or document that is false or misleading in a material particular.
(34) The approving authority may, by written notice to the company, require the company within 30 days after the date of service of the notice to show cause why —(a)
a specified matter in its letter of award should not be amended in the manner specified in the notice; or
(b)
its letter of award should not be revoked.
(35) If the approving authority is satisfied that, having regard to any representation of the company and all the circumstances of the case, it is just and reasonable to do so, the approving authority may —(a)
amend a matter in the letter of award in a manner considered just and reasonable by the approving authority; or
(b)
revoke the letter of award with effect from a date specified by the approving authority.
(36) The approving authority must give a written notice to the company of its decision under subsection (35).
(37) For the purposes of subsection (35), the approving authority may specify any date for the amendment or revocation to take effect, including (if it is just and reasonable to do so) —(a)
a date before the non-compliance or application mentioned in subsection (33); or
(b)
if the provision or condition is to be complied with over a period of time, before the date of commencement of that period.
(38) If a matter in an awardee company’s letter of award is amended under subsection (35)(a), then —(a)
beginning from the effective date of the amendment, a reference in this section to that matter in relation to the company is to that matter as so amended; and
(b)
if the company has been given an amount of RICs pursuant to that letter that would not have been given to it had the amendment been made to the letter before the RICs were given, an amount (called in this section the recoverable amount) equivalent to all of those RICs is recoverable from the company.
(39) If a letter of award is revoked under subsection (35)(b), an amount (also called in this section the recoverable amount) equivalent to all RICs that were given to the company pursuant to that letter for qualifying expenditure incurred after the date of revocation, is recoverable from the company.
(40) The recoverable amount may be recovered from the company in the following manner:(a)
by debiting an amount of RICs that are in the RIC account up to the recoverable amount;
(b)
if there are no RICs in the RIC account, or the amount of such RICs is less than the recoverable amount, by recovering the recoverable amount or the balance thereof from the company as a debt due to the Government.
(41) For the purpose of subsection (40)(a), RICs that were given on a later date are to be debited before RICs given on an earlier date.
(42) For the purpose of subsection (40)(b) —(a)
the amount described in that provision is to be paid at the place stated in a notice served by the Comptroller on the company within 30 days after the service of the notice;
(b)
the Comptroller may, in the Comptroller’s discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment is to be made; and
(c)
sections 86(1) to (6), 87(1) and (2), 89, 90 and 91 apply to the collection and recovery by the Comptroller of that amount as they apply to the collection and recovery of tax.
Where awardee company ceases to exist due to amalgamation
(43) Subsections (44) and (45) apply where —(a)
one of the companies (X) in an amalgamation of companies has, as of the date of amalgamation —(i)
RICs for qualifying expenditure for a qualifying activity for which a letter of confirmation has yet to be given under subsection (17); or
(ii)
unutilised RICs for qualifying expenditure incurred for a qualifying activity;
(b)
the amalgamated company (being a different company from X) (Y) carries on or desires to carry on the qualifying activity; and
(c)
Y applies to the approving authority, within the prescribed period after the date of amalgamation, for X’s letter of award to which those RICs or unutilised RICs relate, to be transferred to Y.[Act 25 of 2025 wef 08/12/2025]
(44) The approving authority may approve the application with or without any modification of the conditions stated in the letter of award as the approving authority considers appropriate.
(45) Upon approval of the application —(a)
the provisions of this section apply as if Y were the awardee company of the letter of award, as modified in accordance with subsection (44); and
(b)
in the case of subsection (43)(a)(ii), the unutilised RICs —(i)
are to be credited to an RIC account kept or to be kept for Y; and
(ii)
are treated as having been given to Y on the date they were given to X by the approving authority under subsection (17), except that this does not affect the debit of any RICs from Y’s RIC account carried out before those unutilised RICs are credited to Y’s RIC account under sub‑paragraph (i).[Act 25 of 2025 wef 08/12/2025]
(45A) If an application is not made in accordance with subsection (43)(c), or if such an application is refused, then the RICs mentioned in subsection (43)(a)(i) or (ii) are treated as forfeited.[Act 25 of 2025 wef 08/12/2025]
(45B) Subsections (45) and (45A) apply despite anything in section 215G(c) of the Companies Act 1967 or section 34C.[Act 25 of 2025 wef 08/12/2025]
Offset of taxes, etc., of related company
(46) Regulations may be made under subsection (51) —(a)
to enable an awardee company (X) to apply to the approving authority for any amount of RICs given to X to be used to offset any due tax of one or more other companies (each called Y) that are of the same group as X at a prescribed time and nominated by X;
(b)
to prescribe the maximum number of Ys that may be nominated for each X and to require X to nominate the same Ys for all of X’s letters of award;
(c)
to apply with modifications the provisions of this section in relation to Y or to each Y as they apply in relation to X, if Y satisfies such requirements as may be prescribed;[Act 25 of 2025 wef 08/12/2025]
(d)
to require X to inform the approving authority if Y or any Y ceases to be part of the same group as X before a prescribed time;
(e)
to provide, in any prescribed circumstances, for the recovery from Y of any amount of RICs that have been used to offset any due tax of Y, and for any RICs that were debited from X’s RIC account to offset that due tax to be credited back to the account;[Act 25 of 2025 wef 08/12/2025]
(ea)
to provide that any amount of RICs —(i)
credited back to X’s RIC account under regulations made for the purpose in paragraph (e); or
(ii)
otherwise wrongly debited from X’s RIC account and credited back to that account,
is treated as having been given to X on the date that it was first given to X under subsection (17), but without affecting any previous debit of RICs from X’s RIC account; and
[Act 25 of 2025 wef 08/12/2025]
(f)
to provide for any other matter necessary or expedient for the nomination of Y, and the application of RICs given to X to offset any due tax of Y or any Y.
(47) In subsection (46) —“FRS 110” means the financial reporting standard known as Financial Reporting Standard 110 (Consolidated Financial Statements) that is treated as made by the Accounting Standards Committee under Part 3 of the Accounting Standards Act 2007, as amended from time to time;
“group” means a group of entities (whether incorporated or registered in Singapore or elsewhere) comprising a parent and its subsidiaries within the meaning of FRS 110.
(48) Despite the application of RICs given to X in offsetting any due tax of Y in accordance with the regulations mentioned in subsection (46)(a) —(a)
X remains responsible for complying with any provision of this Act or the regulations, and with any condition specified in the letter of award in relation to those RICs; and
(b)
action may accordingly be taken against X under subsections (34) to (42) for any non-compliance with such provision or condition.
Recovery of RICs for erroneous offsetting of tax, etc.
(48A) If —(a)
an amount of RICs of an awardee company (X) is used to offset the due tax of any company (including X); or
(b)
a monetary payment equivalent to an amount of RICs of an awardee company (also called X) is paid to X under subsection (31),
otherwise than in accordance with this section or the regulations made under subsection (51), then the amount of the due tax so offset or the amount paid to X is recoverable by the Comptroller from the company or X (as the case may be) as a debt due to the Government.
[Act 25 of 2025 wef 08/12/2025]
(48B) For the purposes of subsection (48A) —(a)
the amount recoverable under that provision is to be paid at the place stated in a notice served by the Comptroller on the company or X (as the case may be) within 30 days after the service of the notice;
(b)
the Comptroller may, in the Comptroller’s discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment is to be made; and
(c)
sections 86(1) to (6), 87(1) and (2), 89, 90 and 91 apply to the collection and recovery by the Comptroller of that amount as they apply to the collection and recovery of tax.[Act 25 of 2025 wef 08/12/2025]
(48C) In a case mentioned in subsection (48A) —(a)
the amount of X’s RICs mentioned in that provision is to be credited back to X’s RIC account; and
(b)
those RICs so credited back are treated as having been given to X on the date that they were first given to X by the approving authority under subsection (17), except that this does not affect any debit of RICs from X’s RIC account carried out before those RICs are so credited back.[Act 25 of 2025 wef 08/12/2025]
(48D) Where —(a)
an amount of RICs is credited back to the RIC account of an awardee company (Y) under subsection (48C) or any regulations made under subsection (51); but
(b)
the payout date or payment date (as the case may be) for those RICs has passed,
then subsections (31) and (32) apply for the purpose of enabling a monetary payment equivalent to the amount of those RICs to be made to Y as if a reference to the payout date or payment date were a reference to a prescribed date after the RICs are credited back to Y’s RIC account.
[Act 25 of 2025 wef 08/12/2025]
Treatment of RIC and expenditure for which RICs are given
(49) Despite anything in this Act —(a)
RICs given to an awardee company are treated as a grant from the Government to the company; and
(b)
an amount of the qualifying expenditure equivalent to RICs given is treated for the purposes of Parts 5, 6 and 9 as expenditure subsidised by a grant from the Government.
(50) Regulations may be made under subsection (51) to provide for the reversal of any tax treatment (arising under subsection (49)) necessitated by an amount equivalent to any RICs becoming recoverable because of subsection (38) or (39).
Regulations
(51) The Minister may make regulations to carry out the purposes and provisions of this section.[Act 35 of 2024 wef 27/11/2024]
—(1) This section provides for tax credits to be given for qualifying expenditure incurred by companies, to be offset against any income tax levied on, and any penalty, surcharge or interest related to income tax and due from, the companies, and for unutilised tax credits to be paid to the companies.
(2) In this section —“awardee company” means a company given a letter of award under subsection (4);
“claim period”, in relation to a company given a letter of award, means the period mentioned in subsection (5)(h) that is specified in the letter of award;
“date of amalgamation” means the date shown on the notice of amalgamation under section 215F of the Companies Act 1967;
“DTT” and “MTT” have the meanings given by section 2(1) of the MMT Act, and includes any penalty, surcharge or interest payable to the Comptroller under that Act;
“due tax” has the meaning given by subsection (24);
“letter of award” means a letter of award given under subsection (4);
“letter of confirmation” means a letter of confirmation given under subsection (17);
“MMT Act” means the Multinational Enterprise (Minimum Tax) Act 2024;
“payment date” has the meaning given by subsection (23);
“payout date”, in relation to a company given a letter of confirmation, means the date mentioned in subsection (20) that is specified in the letter;
“qualifying activity” means any activity prescribed as a qualifying activity by regulations made under subsection (51);
“qualifying expenditure” means any expenditure specified in the letter of award concerned, incurred in carrying out the qualifying activity specified in the letter;
“qualifying period”, in relation to a company given a letter of award, means the period mentioned in subsection (5)(c) that is specified in the letter;
“recoverable amount” has the meaning given by subsection (38) or (39), as the case may be;
“RIC” or “refundable investment credit” means a tax credit given to an awardee company under this section for qualifying expenditure incurred in carrying out a qualifying activity;
“RIC account” means an account kept by that name under subsection (22) or (45);
“tax” includes any penalty, surcharge or interest payable to the Comptroller under this Act, other than an amount payable to the Comptroller as withholding tax;
“unutilised RICs” means RICs given to an awardee company that have not been —(a)
used to offset any tax, DTT or MTT that is levied on or due from the awardee company, or another company in the same group as the awardee company under regulations made for the purpose of subsection (46);
(b)
debited from the RIC account of the company under subsection (40)(a) (including that provision as applied by subsections (14A) and (20B)); or[Act 25 of 2025 wef 08/12/2025]
(c)
paid to the awardee company.
(3) A company engaged in, or which desires to engage in, a qualifying activity may apply to the Minister or an authorised body (called in this section the approving authority), in the form and manner determined by the approving authority, for approval to be given RICs for qualifying expenditure incurred in carrying out that activity.
(4) The approving authority may, if the approving authority considers it expedient in the public interest to do so, approve the application and issue to the company a letter of award.
(5) Each letter of award must state —(a)
the qualifying activity for which the approval is given;
(b)
the type or types of qualifying expenditure in carrying out the qualifying activity for which RICs may be given;
(c)
the period (called in this section the qualifying period) in which the qualifying expenditure is to be incurred, which must not exceed 10 years;
(d)
the maximum amount of RICs to be given for all the qualifying expenditure and the maximum amount of RICs to be given for each type of qualifying expenditure, as determined by the approving authority;
(e)
the rate or rates used in computing the amount of RICs;
(f)
the conditions to be complied with for the company to be given or to retain an amount of RICs;
(g)
any other condition (called in this section an additional condition) that must be complied with for a specified part of the first maximum amount of RICs mentioned in paragraph (d) to be given;
(h)
the period (called in this section the claim period) within which the company may claim for an amount of RICs; and
(i)
the last day by which unutilised RICs are to be paid to the company, which must not be later than 4 years starting from the date that the company makes the application under subsection (15) pursuant to which those RICs were given.[Act 25 of 2025 wef 08/12/2025]
(6) For the purposes of subsection (5)(b), (c), (f) and (g), the approving authority may specify different qualifying expenditures, different qualifying periods, and different conditions for different types of qualifying activities.
(7) For the purpose of subsection (5)(c), the approving authority may specify a qualifying period that begins from a date before the date of commencement of section 30 of the Income Tax (Amendment) Act 2024, but not earlier than 1 July 2024.
(8) For the purpose of subsection (5)(e), the regulations may specify one or more rates for computing the amount of RICs for each type of qualifying expenditure, and prescribe the factors which the approving authority must consider in determining the rate to specify for that type of qualifying expenditure in each letter of award.
(9) For the purpose of this section, a reference to RIC for each type of qualifying expenditure is to the RICs computed using the rate specified for that type of qualifying expenditure in the letter of award.
(10) Where the approving authority approves an application by a company for 2 or more qualifying activities, the approving authority may issue a single letter of award for those activities if the approving authority is satisfied that the company is engaged in or desires to engage in all those activities as part of the same project.
(11) No approval may be given after 31 December 2029.
(12) The approving authority may, on the application of an awardee company, amend any of the following matters in the letter of award:(a)
the qualifying activity;
(b)
the type or types of qualifying expenditure for carrying out the qualifying activity for which RICs may be given;
(c)
the commencement or end date of the qualifying period, except that the total period after the amendment must not exceed 10 years;
(d)
the maximum amount of RICs to be given for all the qualifying expenditure or the maximum amount of RICs to be given for each type of qualifying expenditure;
(e)
any rate used in computing the amount of RICs;
(f)
any condition (including any additional condition);
(g)
any claim period;
(h)
the last day by which any unutilised RICs must be paid to the company, which must not be later than 4 years starting from the date that the company makes the application under subsection (15) pursuant to which those RICs were given.[Act 25 of 2025 wef 08/12/2025]
(13) Subsection (12) does not prevent the approving authority from making any amendment to correct any error in the letter of award.
(14) If the approving authority approves an application to amend a matter in subsection (12), a reference in this section to that matter in relation to the company is to that matter as so amended.
(14A) Subsections (38)(b), (40), (41) and (42) apply with the necessary modifications to an amendment of a letter of award under subsection (13) or (14) as they apply to an amendment of a letter of award under subsection (35)(a).[Act 25 of 2025 wef 08/12/2025]
(15) After an awardee company has incurred in its qualifying period an amount of qualifying expenditure specified in its letter of award in carrying out the qualifying activity specified in the letter, the awardee company may apply to the approving authority for an amount of RICs stated in the letter for that amount and type of the expenditure.
(16) The application must be made within the claim period or such extended period as the approving authority may allow, and must be accompanied by such information and documents as the approving authority may require.
(17) If, the approving authority is satisfied that —(a)
the awardee company has incurred any qualifying expenditure; and
(b)
the awardee company has complied with every condition that is to be complied with by a date that is on or before the date of the application, or it is just and reasonable, having regard to any representation of the company and all relevant circumstances of the case, to treat every such condition as having been complied with,
the approving authority must, by a letter of confirmation to the awardee company, give to the company an amount of RICs for the type or types of qualifying expenditure to which the qualifying expenditure in paragraph (a) belongs, as determined by subsections (18) and (19).
(18) Subject to subsection (19), the amount of RICs for each type of qualifying expenditure is the lesser of —(a)
the maximum amount of RICs specified in the letter of award less any RICs already given for that type of qualifying expenditure in previous letters of confirmation pursuant to the same letter of award; and
(b)
an amount determined by the formula
where —
(i)
A is the amount of the qualifying expenditure incurred and not claimed in previous letters of confirmation pursuant to the same letter of award; and
(ii)
B is the rate specified in the letter of award that applies to that type of qualifying expenditure.
(19) The amount of RICs given by a letter of confirmation must not exceed the maximum amount of RICs that may be given for all qualifying expenditure as specified in the letter of award, less —(a)
any RICs given in previous letters of confirmation pursuant to the same letter of award; and
(b)
if any additional condition has yet to be complied with, the specified part of the maximum amount of RICs that may only be given upon compliance.
(20) The letter of confirmation must state the payout date for unutilised RICs, which must not be later than the last day specified in the letter of award under subsection (5)(i) as amended (if applicable) under subsection (12).
(20A) The approving authority may, in any prescribed circumstances, on the application by an awardee company or on its own initiative, amend any matter stated in a letter of confirmation given to the awardee company.[Act 25 of 2025 wef 08/12/2025]
(20B) Where an amendment is made to a letter of confirmation under subsection (20A) —(a)
a reference in this section to that matter in relation to the awardee company is to that matter as so amended; and
(b)
subsections (38)(b), (40), (41) and (42) apply with the necessary modifications to the amendment as they apply to an amendment of a letter of award under subsection (35)(a), and for this purpose, a reference to the letter of award in subsection (38)(b) is to the letter of confirmation.[Act 25 of 2025 wef 08/12/2025]
(21) To avoid doubt, the approving authority may issue one or more letters of confirmation to the awardee company in respect of each letter of award issued to the company.
(22) The RICs given to the awardee company must be credited to an account called the “RIC account” for the purposes of this section.
(23) Regulations may be made under subsection (51) —(a)
to allow, in any prescribed circumstances, an awardee company to make an election for any amount of RICs given to it to be paid to it in a specified manner and on a date specified by the approving authority (called in this section the payment date), which must not be later than 4 years starting from the date that the company makes the application under subsection (15) pursuant to which those RICs were given; and [Act 25 of 2025 wef 08/12/2025]
(b)
to provide for the revocation of such election and the circumstances under which such election is treated as revoked, and other matters relating to such election.[Act 25 of 2025 wef 08/12/2025]
(24) Subsections (25) to (29) apply where —(a)
there are RICs in an RIC account of an awardee company;
(b)
either —(i)
an amount of tax is levied on or due from the company under this Act; or
(ii)
an amount of DTT or MTT is levied on or due from the company under the MMT Act,
(each called in this section due tax); and
(c)
the company has not made an election under regulations made under subsection (23) for those RICs to be paid to the company.
(25) Subject to the regulations made under subsection (51), the Comptroller must —(a)
offset an amount of the due tax against the credit in the RIC account that is the lower of the due tax and the credit in the RIC account; and
(b)
debit the company’s RIC account with such amount.
(26) When the Comptroller offsets an amount of due tax against the RIC account of an awardee company under subsection (25), that amount of due tax is treated as paid, and the Comptroller must give notice of such payment to the awardee company.
(27) If —(a)
an awardee company has more than one due tax; and
(b)
the credit in its RIC account is less than the sum of the amounts of those due taxes,
the Comptroller may determine in a manner he or she considers reasonable —
(c)
the due tax or due taxes to be offset under subsection (25); and
(d)
if the credit is sufficient to offset more than one due tax, the order and amount by which the due taxes are to be offset under that subsection.
(28) RICs in an RIC account that are given on an earlier date are to be fully applied to offset due taxes under subsection (25) before RICs in the same account that are given on a later date.
(29) RICs remaining in an RIC account may not be applied to offset due taxes under subsection (25) after the prescribed day before the payout date.
(30) Subsections (31) and (32) apply where —(a)
on the prescribed day before the payout date, there are RICs remaining in an RIC account of an awardee company; or
(b)
an awardee company has made an election under regulations made for the purpose of subsection (23) for any RICs given to it to be paid to it by the payment date, and the prescribed day before the payment date has arrived.
(31) The Comptroller is to make a monetary payment equivalent to the amount of those RICs to the awardee company on or before the payout date or payment date, to the extent that they have not been —(a)
revoked, or treated as revoked under the regulations; or
(b)
debited under subsection (40)(a) (including that provision as applied by subsections (14A) and (20B)).[Act 25 of 2025 wef 08/12/2025]
(32) Upon the making of the payment, those RICs are to be debited from the RIC account of the awardee company.
(33) Subsections (34) to (42) apply where the approving authority is satisfied that an awardee company —(a)
has not complied with a provision of this Act or regulations made under subsection (51);
(b)
has not complied with a condition (including any additional condition) in its letter of award by the date it is to be complied with; or
(c)
in an application to the approving authority, provided any information or document that is false or misleading in a material particular.
(34) The approving authority may, by written notice to the company, require the company within 30 days after the date of service of the notice to show cause why —(a)
a specified matter in its letter of award should not be amended in the manner specified in the notice; or
(b)
its letter of award should not be revoked.
(35) If the approving authority is satisfied that, having regard to any representation of the company and all the circumstances of the case, it is just and reasonable to do so, the approving authority may —(a)
amend a matter in the letter of award in a manner considered just and reasonable by the approving authority; or
(b)
revoke the letter of award with effect from a date specified by the approving authority.
(36) The approving authority must give a written notice to the company of its decision under subsection (35).
(37) For the purposes of subsection (35), the approving authority may specify any date for the amendment or revocation to take effect, including (if it is just and reasonable to do so) —(a)
a date before the non-compliance or application mentioned in subsection (33); or
(b)
if the provision or condition is to be complied with over a period of time, before the date of commencement of that period.
(38) If a matter in an awardee company’s letter of award is amended under subsection (35)(a), then —(a)
beginning from the effective date of the amendment, a reference in this section to that matter in relation to the company is to that matter as so amended; and
(b)
if the company has been given an amount of RICs pursuant to that letter that would not have been given to it had the amendment been made to the letter before the RICs were given, an amount (called in this section the recoverable amount) equivalent to all of those RICs is recoverable from the company.
(39) If a letter of award is revoked under subsection (35)(b), an amount (also called in this section the recoverable amount) equivalent to all RICs that were given to the company pursuant to that letter for qualifying expenditure incurred after the date of revocation, is recoverable from the company.
(40) The recoverable amount may be recovered from the company in the following manner:(a)
by debiting an amount of RICs that are in the RIC account up to the recoverable amount;
(b)
if there are no RICs in the RIC account, or the amount of such RICs is less than the recoverable amount, by recovering the recoverable amount or the balance thereof from the company as a debt due to the Government.
(41) For the purpose of subsection (40)(a), RICs that were given on a later date are to be debited before RICs given on an earlier date.
(42) For the purpose of subsection (40)(b) —(a)
the amount described in that provision is to be paid at the place stated in a notice served by the Comptroller on the company within 30 days after the service of the notice;
(b)
the Comptroller may, in the Comptroller’s discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment is to be made; and
(c)
sections 86(1) to (6), 87(1) and (2), 89, 90 and 91 apply to the collection and recovery by the Comptroller of that amount as they apply to the collection and recovery of tax.
(43) Subsections (44) and (45) apply where —(a)
one of the companies (X) in an amalgamation of companies has, as of the date of amalgamation —(i)
RICs for qualifying expenditure for a qualifying activity for which a letter of confirmation has yet to be given under subsection (17); or
(ii)
unutilised RICs for qualifying expenditure incurred for a qualifying activity;
(b)
the amalgamated company (being a different company from X) (Y) carries on or desires to carry on the qualifying activity; and
(c)
Y applies to the approving authority, within the prescribed period after the date of amalgamation, for X’s letter of award to which those RICs or unutilised RICs relate, to be transferred to Y.[Act 25 of 2025 wef 08/12/2025]
(44) The approving authority may approve the application with or without any modification of the conditions stated in the letter of award as the approving authority considers appropriate.
(45) Upon approval of the application —(a)
the provisions of this section apply as if Y were the awardee company of the letter of award, as modified in accordance with subsection (44); and
(b)
in the case of subsection (43)(a)(ii), the unutilised RICs —(i)
are to be credited to an RIC account kept or to be kept for Y; and
(ii)
are treated as having been given to Y on the date they were given to X by the approving authority under subsection (17), except that this does not affect the debit of any RICs from Y’s RIC account carried out before those unutilised RICs are credited to Y’s RIC account under sub‑paragraph (i).[Act 25 of 2025 wef 08/12/2025]
(45A) If an application is not made in accordance with subsection (43)(c), or if such an application is refused, then the RICs mentioned in subsection (43)(a)(i) or (ii) are treated as forfeited.[Act 25 of 2025 wef 08/12/2025]
(45B) Subsections (45) and (45A) apply despite anything in section 215G(c) of the Companies Act 1967 or section 34C.[Act 25 of 2025 wef 08/12/2025]
(46) Regulations may be made under subsection (51) —(a)
to enable an awardee company (X) to apply to the approving authority for any amount of RICs given to X to be used to offset any due tax of one or more other companies (each called Y) that are of the same group as X at a prescribed time and nominated by X;
(b)
to prescribe the maximum number of Ys that may be nominated for each X and to require X to nominate the same Ys for all of X’s letters of award;
(c)
to apply with modifications the provisions of this section in relation to Y or to each Y as they apply in relation to X, if Y satisfies such requirements as may be prescribed;[Act 25 of 2025 wef 08/12/2025]
(d)
to require X to inform the approving authority if Y or any Y ceases to be part of the same group as X before a prescribed time;
(e)
to provide, in any prescribed circumstances, for the recovery from Y of any amount of RICs that have been used to offset any due tax of Y, and for any RICs that were debited from X’s RIC account to offset that due tax to be credited back to the account;[Act 25 of 2025 wef 08/12/2025]
(ea)
to provide that any amount of RICs —(i)
credited back to X’s RIC account under regulations made for the purpose in paragraph (e); or
(ii)
otherwise wrongly debited from X’s RIC account and credited back to that account,
is treated as having been given to X on the date that it was first given to X under subsection (17), but without affecting any previous debit of RICs from X’s RIC account; and
[Act 25 of 2025 wef 08/12/2025]
(f)
to provide for any other matter necessary or expedient for the nomination of Y, and the application of RICs given to X to offset any due tax of Y or any Y.
(47) In subsection (46) —“FRS 110” means the financial reporting standard known as Financial Reporting Standard 110 (Consolidated Financial Statements) that is treated as made by the Accounting Standards Committee under Part 3 of the Accounting Standards Act 2007, as amended from time to time;
“group” means a group of entities (whether incorporated or registered in Singapore or elsewhere) comprising a parent and its subsidiaries within the meaning of FRS 110.
(48) Despite the application of RICs given to X in offsetting any due tax of Y in accordance with the regulations mentioned in subsection (46)(a) —(a)
X remains responsible for complying with any provision of this Act or the regulations, and with any condition specified in the letter of award in relation to those RICs; and
(b)
action may accordingly be taken against X under subsections (34) to (42) for any non-compliance with such provision or condition.
(48A) If —(a)
an amount of RICs of an awardee company (X) is used to offset the due tax of any company (including X); or
(b)
a monetary payment equivalent to an amount of RICs of an awardee company (also called X) is paid to X under subsection (31),
otherwise than in accordance with this section or the regulations made under subsection (51), then the amount of the due tax so offset or the amount paid to X is recoverable by the Comptroller from the company or X (as the case may be) as a debt due to the Government.
[Act 25 of 2025 wef 08/12/2025]
(48B) For the purposes of subsection (48A) —(a)
the amount recoverable under that provision is to be paid at the place stated in a notice served by the Comptroller on the company or X (as the case may be) within 30 days after the service of the notice;
(b)
the Comptroller may, in the Comptroller’s discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment is to be made; and
(c)
sections 86(1) to (6), 87(1) and (2), 89, 90 and 91 apply to the collection and recovery by the Comptroller of that amount as they apply to the collection and recovery of tax.[Act 25 of 2025 wef 08/12/2025]
(48C) In a case mentioned in subsection (48A) —(a)
the amount of X’s RICs mentioned in that provision is to be credited back to X’s RIC account; and
(b)
those RICs so credited back are treated as having been given to X on the date that they were first given to X by the approving authority under subsection (17), except that this does not affect any debit of RICs from X’s RIC account carried out before those RICs are so credited back.[Act 25 of 2025 wef 08/12/2025]
(48D) Where —(a)
an amount of RICs is credited back to the RIC account of an awardee company (Y) under subsection (48C) or any regulations made under subsection (51); but
(b)
the payout date or payment date (as the case may be) for those RICs has passed,
then subsections (31) and (32) apply for the purpose of enabling a monetary payment equivalent to the amount of those RICs to be made to Y as if a reference to the payout date or payment date were a reference to a prescribed date after the RICs are credited back to Y’s RIC account.
[Act 25 of 2025 wef 08/12/2025]
(49) Despite anything in this Act —(a)
RICs given to an awardee company are treated as a grant from the Government to the company; and
(b)
an amount of the qualifying expenditure equivalent to RICs given is treated for the purposes of Parts 5, 6 and 9 as expenditure subsidised by a grant from the Government.
(50) Regulations may be made under subsection (51) to provide for the reversal of any tax treatment (arising under subsection (49)) necessitated by an amount equivalent to any RICs becoming recoverable because of subsection (38) or (39).
(51) The Minister may make regulations to carry out the purposes and provisions of this section.[Act 35 of 2024 wef 27/11/2024]
Recovery of cash grant from companies
93C.—(1) Where a company receives a cash grant under any provision of this Part (other than a grant given under section 92B, 92C, 92J or 93B) —(a)
without having satisfied all the requirements to qualify for the cash grant; or
(b)
that is in excess of that which may be given to the company under that provision,
the amount of the cash grant or the excess amount of the cash grant (as the case may be) is recoverable by the Comptroller from the company as a debt due to the Government.
(2) The Comptroller must send the company a notice specifying the amount to be repaid under subsection (1), and the company must pay the amount at the place stated in the notice within one month after the service of the notice.
(3) The Comptroller may, in his or her discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment under subsection (2) is to be made.
(4) Sections 57, 87(1) and (2), 89 and 90 apply with the necessary modifications to the collection and recovery by the Comptroller of the amounts recoverable under subsection (1) as they apply to the collection and recovery of tax.
(5) Without affecting subsections (2), (3) and (4), where an amount of cash grant (other than a grant under section 93B) (amount A) is to be made to a company under a provision of this Part and an amount of another cash grant (other than a grant under section 93B) (amount B) that was previously made to a company under another provision of this Part is recoverable by the Comptroller as a debt due to the Government under subsection (1), section 92B(4), 92C(5) or 92J(6), then —(a)
despite the firstmentioned provision, amount A is reduced by amount B; and
(b)
the amount of the reduction is treated as a repayment by the company of the debt due to the Government.
(6) In addition, where an amount of cash grant (other than a grant under section 93B) is to be made to the company under a provision of this Part and any tax, duty, interest or penalty is due from the company —(a)
under this Act to the Comptroller of Income Tax;
(b)
under the Goods and Services Tax Act 1993 to the Comptroller of Goods and Services Tax;
(c)
under the Property Tax Act 1960 to the Comptroller of Property Tax; or
(d)
under the Stamp Duties Act 1929 to the Commissioner of Stamp Duties,
then —
(e)
despite that provision, the amount of cash grant to be made by the Comptroller to the company must be reduced by the amount so due; and
(f)
the amount of the reduction is treated as tax, duty, interest or penalty paid by the company under the relevant Act and must (if it is due under an Act other than this Act) be paid by the Comptroller to the Comptroller of Goods and Services Tax, the Comptroller of Property Tax or the Commissioner of Stamp Duties, as the case may be.
(7) Where the amount of cash grant to be made to the company is less than the sum of the amount of cash grant recoverable by the Comptroller from the company under subsection (5) and the amount of tax, duty, interest or penalty due by the company under subsection (6), the Comptroller may determine the amount of reduction to be made under subsection (5) or (6), or both, in a manner that he or she considers reasonable.[Act 25 of 2025 wef 08/12/2025]
—(1) Where a company receives a cash grant under any provision of this Part (other than a grant given under section 92B, 92C, 92J or 93B) —(a)
without having satisfied all the requirements to qualify for the cash grant; or
(b)
that is in excess of that which may be given to the company under that provision,
the amount of the cash grant or the excess amount of the cash grant (as the case may be) is recoverable by the Comptroller from the company as a debt due to the Government.
(2) The Comptroller must send the company a notice specifying the amount to be repaid under subsection (1), and the company must pay the amount at the place stated in the notice within one month after the service of the notice.
(3) The Comptroller may, in his or her discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment under subsection (2) is to be made.
(4) Sections 57, 87(1) and (2), 89 and 90 apply with the necessary modifications to the collection and recovery by the Comptroller of the amounts recoverable under subsection (1) as they apply to the collection and recovery of tax.
(5) Without affecting subsections (2), (3) and (4), where an amount of cash grant (other than a grant under section 93B) (amount A) is to be made to a company under a provision of this Part and an amount of another cash grant (other than a grant under section 93B) (amount B) that was previously made to a company under another provision of this Part is recoverable by the Comptroller as a debt due to the Government under subsection (1), section 92B(4), 92C(5) or 92J(6), then —(a)
despite the firstmentioned provision, amount A is reduced by amount B; and
(b)
the amount of the reduction is treated as a repayment by the company of the debt due to the Government.
(6) In addition, where an amount of cash grant (other than a grant under section 93B) is to be made to the company under a provision of this Part and any tax, duty, interest or penalty is due from the company —(a)
under this Act to the Comptroller of Income Tax;
(b)
under the Goods and Services Tax Act 1993 to the Comptroller of Goods and Services Tax;
(c)
under the Property Tax Act 1960 to the Comptroller of Property Tax; or
(d)
under the Stamp Duties Act 1929 to the Commissioner of Stamp Duties,
then —
(e)
despite that provision, the amount of cash grant to be made by the Comptroller to the company must be reduced by the amount so due; and
(f)
the amount of the reduction is treated as tax, duty, interest or penalty paid by the company under the relevant Act and must (if it is due under an Act other than this Act) be paid by the Comptroller to the Comptroller of Goods and Services Tax, the Comptroller of Property Tax or the Commissioner of Stamp Duties, as the case may be.
(7) Where the amount of cash grant to be made to the company is less than the sum of the amount of cash grant recoverable by the Comptroller from the company under subsection (5) and the amount of tax, duty, interest or penalty due by the company under subsection (6), the Comptroller may determine the amount of reduction to be made under subsection (5) or (6), or both, in a manner that he or she considers reasonable.[Act 25 of 2025 wef 08/12/2025]
Source: Singapore Statutes Online (Attorney-General's Chambers), © Government of Singapore.
