§ 49 — Assessment

49.—(1) This section applies where —(a)

a return required to be furnished under section 41 or 43 has not been furnished by the due date mentioned in that section; or

(b)

it appears to the Comptroller that a return is incomplete, incorrect or not furnished in accordance with the requirements of section 41 or 43.

(2) The Comptroller may make an assessment of MTT or DTT, or both, on a chargeable entity of an MNE group for the financial year in question, according to the best of the Comptroller’s judgment.

(3) More than one assessment may be made under subsection (2).

(4) An assessment is to be made no later than —(a)

in the case of MTT — 31 December of the 5th year after the year in which the due date mentioned in section 41(3)(a) or (b) (whichever is applicable) falls; and

(b)

in the case of DTT — 31 December of the 5th year after the financial year to which the DTT relates.Example

Assuming the financial year of an MNE group ends on 30 June 2026, the tax returns for MTT and DTT will be due on 30 September 2027 (or 31 December 2027 if the financial year is the transition year).

The Comptroller may make an assessment of MTT on a chargeable entity no later than 31 December 2032, i.e. the 5th year after the year in which the tax return for MTT is due (which is either 30 September 2027 or 31 December 2027). The Comptroller may also make an assessment of DTT on a chargeable entity no later than 31 December 2031, i.e. the 5th year after the financial year to which the DTT relates (which is the financial year ending on 30 June 2026).

[Act 25 of 2025 wef 01/01/2025]

(5) The Comptroller must serve a notice of the assessment on the chargeable entity of the MNE group for the MTT or DTT assessed to be payable.

(6) Despite any objection or appeal against the assessment, a chargeable entity of the MNE group must make payment to the Comptroller of the MTT or DTT assessed, or the balance of the amount still unpaid (as the case may be).

(7) Payment under subsection (6) must be made —(a)

in the manner stated in the notice within one month after service of the notice; and

(b)

in Singapore dollars.

(8) 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, allow an extension of time for making the payment.

—(1) This section applies where —(a)

a return required to be furnished under section 41 or 43 has not been furnished by the due date mentioned in that section; or

(b)

it appears to the Comptroller that a return is incomplete, incorrect or not furnished in accordance with the requirements of section 41 or 43.

(2) The Comptroller may make an assessment of MTT or DTT, or both, on a chargeable entity of an MNE group for the financial year in question, according to the best of the Comptroller’s judgment.

(3) More than one assessment may be made under subsection (2).

(4) An assessment is to be made no later than —(a)

in the case of MTT — 31 December of the 5th year after the year in which the due date mentioned in section 41(3)(a) or (b) (whichever is applicable) falls; and

(b)

in the case of DTT — 31 December of the 5th year after the financial year to which the DTT relates.Example

Assuming the financial year of an MNE group ends on 30 June 2026, the tax returns for MTT and DTT will be due on 30 September 2027 (or 31 December 2027 if the financial year is the transition year).

The Comptroller may make an assessment of MTT on a chargeable entity no later than 31 December 2032, i.e. the 5th year after the year in which the tax return for MTT is due (which is either 30 September 2027 or 31 December 2027). The Comptroller may also make an assessment of DTT on a chargeable entity no later than 31 December 2031, i.e. the 5th year after the financial year to which the DTT relates (which is the financial year ending on 30 June 2026).

[Act 25 of 2025 wef 01/01/2025]

(5) The Comptroller must serve a notice of the assessment on the chargeable entity of the MNE group for the MTT or DTT assessed to be payable.

(6) Despite any objection or appeal against the assessment, a chargeable entity of the MNE group must make payment to the Comptroller of the MTT or DTT assessed, or the balance of the amount still unpaid (as the case may be).

(7) Payment under subsection (6) must be made —(a)

in the manner stated in the notice within one month after service of the notice; and

(b)

in Singapore dollars.

(8) 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, allow an extension of time for making the payment.