Request for More Information

After reviewing the application, IRAS may write to you or your authorised tax agent for additional information to process your ruling request. We will process your ruling request only when the additional information has been submitted.

To help us expedite the review of your application, please ensure that you provide complete/ detailed information in your ruling requests.

Please note that under certain circumstances, IRAS will not or may decline to rule, i.e. your application may not be accepted.

Application Processing Time

Applications for rulings will generally be processed on a first-come-first-serve basis. Generally, we will give a ruling within 8 weeks of receiving all necessary information. If the request is complex and we require more time, we will keep you informed.

The expected timeline after you have submitted an application for an income tax advance ruling is as follows:

 ActivityRemarks

1

IRAS receives paper copy of Advance Ruling application

IRAS will acknowledge receipt of the application via email within 3 working days of receipt of the application.

2

IRAS issues first query letter with a view to accept the application [1]

Within four weeks of receipt of paper copy of application.

3

IRAS receives Applicant's reply

 

4

IRAS issues second query letter

Within four weeks of receipt of first reply.

5

IRAS receives Applicant's reply

 

6

IRAS issues letter of offer/ IRAS rejects the application

Within four weeks of receipt of second reply.

IRAS assumes that full information has been made available at this stage.  If otherwise, IRAS reserves the right to request for further information.

7

IRAS receives Applicant's acceptance  of offer letter

 

8

IRAS issues Advance Ruling

Within 8 weeks from date of receipt of acceptance letter or complete information, whichever is later.

[1] IRAS may decline to give a ruling/ will not give a ruling if the application falls within paragraphs 1, 2 and/ or 3 of Part I of the Seventh Schedule of the Income Tax Act, Revised Edition 2014 or the information in the ruling application is incomplete.

As applicants are generally in the position to plan and put in an advance ruling application, IRAS will not agree to requests for express rulings except in exceptional circumstances where there are good and valid reasons, and only if IRAS' resources permit. IRAS does not accept the following reasons (non-exhaustive) as grounds for express rulings:

  1. The ruling is required to finalise the proposed structure / transaction so that the applicant can proceed with the next steps;
  2. The listing of the proposed structure / proposed transaction is targeted to take place soon;
  3. The ruling is required to obtain certainty of the tax treatment of the proposed transaction before filing tax return/ completion of a deal/ Board meeting

In the exceptional circumstance where IRAS agrees to a request for an express ruling, we will issue the Advance Ruling within 6 weeks from the date of receipt of acceptance letter or complete information, whichever is later. 

Application Outcomes

Applications may be accepted or not accepted.

  1. Application Accepted
  2. You will be informed when you can expect the ruling to be issued and the estimated amount of total fees payable. You will be required to confirm in writing your acceptance of the terms under which the ruling is to be issued.

  3. Application Not Accepted
  4. You will be informed of the non-acceptance and the reason(s). The application fee of S$620 will not be refunded.

Withdrawing Your Application

You can withdraw your ruling request any time before the ruling is given. The withdrawal must be made in writing.

Withdrawing before the confirmation of your acceptance

If you withdraw before the ruling is given and also before you confirm in writing your acceptance of the terms under which the ruling is to be issued, no additional fees are payable. The application fee of S$620 will not be refunded.

Withdrawing after the confirmation of your acceptance

If you withdraw after you confirm in writing your acceptance of the terms under which the ruling is to be issued but before the ruling is given, you will have to pay the further time-based fee, reimbursement fee (if any) and additional fee (if applicable) chargeable for the time spent on the review of your ruling request up to the time of receipt of your withdrawal. These fees are on top of the application fee of S$620.

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