To obtain an advance ruling from IRAS, you are required to submit an application form along with the required fees and provide details of the arrangement as required.

Eligibility to Apply

Single Applicant: You may apply in your own right or on behalf of a person who has yet to come into legal existence.

Joint Applicants: Two or more persons may also jointly apply.

Authorised Agent: If an agent is making the ruling request on your behalf, you need to authorise the agent in Section E of the Application form for income tax advance ruling (DOCX, 160KB).

Documents to Submit

You have to submit the following before the date of the proposed arrangement:

  1. Application form for income tax advance ruling (DOCX, 160KB).

  2. A written ruling request providing:
    1. Full particulars of the arrangement in question comprising:
      • a comprehensive description of the proposed arrangement and the period concerned;
      • background of the parties to the arrangement;
      • business reasons for the arrangement, if applicable;
      • copies of all relevant documents with the relevant parts or passages identified;
    2. the issue(s) to be considered;
    3. the propositions of the law that relate to the issues raised in the request. 
      This should include:
      • sections of the Income Tax Act that are relevant to the request;
      • appropriate case laws, if any, and legal reasons that support the applicant's interpretation of the said section(s) involved; and
      • possible argument contrary to the interpretation proposed and legal reasons and authoritative support, if any, for these arguments;
    4. whether a previous request has been made on the same or similar arrangement. If so, the outcome of the request and reference of the ruling issued, if applicable; and
    5. a draft ruling.

Template for Written Ruling Request

You may submit the written ruling request using the template attached as Appendix 1 to the Application form for income tax advance ruling (DOCX, 160KB).

Please note that we may decline to accept your ruling application if any of the above information is not provided in the written ruling request.

Additional Information Required for Sale of Property/Shares

To enable us to expedite the review of your ruling request, you will need to submit additional information if the arrangement involves Sale of property (PDF, 66KB) or Sale of shares (PDF, 59KB). As the matter on which the ruling is sought would require IRAS to determine a question of fact, we can, at our discretion, decline to make a ruling after reviewing the additional information submitted.

Submission of Documents

Please address your application and ruling request to:

  1. Assistant Commissioner (Corporate Tax Division) and submit them via email to CTRuling@iras.gov.sg
    - for applicants making the ruling requests with regard to arrangements concerning Corporate Income Tax matter; or 

      1. Assistant Commissioner (Individual Income Tax Division) and submit them via email to IIT_RC@iras.gov.sg
        - for applicants making the ruling requests with regard to arrangements concerning Individual Income Tax matter.  
          1.  

            Fees Payable

            When you apply for an advance ruling, the aggregate of the following fees would be payable:

            Fees Payable for ruling applications made on or after 1 May 2019   When to Pay

            1. Application fee

             

             S$660 

             

            It is non-refundable even if IRAS declines to accept your ruling request (for example: where the arrangement is hypothetical). This fee takes into account the time taken to determine if we are able to accept the ruling request.

            Payable when submitting the advance ruling application form to IRAS.

            2. Further time-based fee

            An hourly rate of S$165 (inclusive of GST) for each hour or part-thereof subsequent to the first 4 hours taken to provide the ruling.

             

             

            3. Additional fee

            In the exceptional circumstance where we have agreed to the request for express ruling, you will be charged an additional fee (in addition to the application fee and further time-based fee above) of up to one time the aggregate of the application fee and further time-based fee above.

            If IRAS accepts your ruling application after its review, you will be informed of an estimate of the further time-based fee and additional fee payable (for express rulings) based on the estimated time that IRAS will spend to provide the ruling (“estimated fees”) in IRAS’ letter of offer to rule.

             

            To facilitate timely collection of such fees, you must pay the estimated fees when you accept IRAS’ offer to provide a ruling.

             

            Upon the issue of the ruling or if you withdraw your ruling request after accepting IRAS’ offer to rule, you will be informed of the actual fees payable (based on actual time spent by IRAS) to provide the ruling or process the ruling request up to the point of your withdrawal respectively.

             

            Where the actual fees are more than the estimated fees already paid, IRAS will issue an invoice to collect the actual fees in excess of the estimated fees. Payment must be made within 30 days from the date of IRAS’ invoice.

            Where the actual fees are less than the estimated fees already paid, IRAS will  refund you the estimated fees paid in excess within 15 working days after IRAS informs you of the actual fees, provided that all information for a refund via interbank transfer has been made available to IRAS.

             

            4. Reimbursement fee

             

            Any costs and reasonable disbursements incurred by IRAS in relation to the ruling and any fees paid by us for external professional advice must be reimbursed by the applicant. We will seek your agreement before obtaining any external professional advice. 

            Payable within 30 days from the date of IRAS’ invoice which will be sent to you.

             

              How to pay

              You can pay via Internet Banking Fund Transfer / Telegraphic Transfer to IRAS' bank account as stated below:

               DescriptionDetails
               PayeeInland Revenue Authority of Singapore
               DBS Current Account Number0010516000 - SGD
               DBS Bank / Branch Code7171 / 001
               DBS Bank Swift CodeDBSSSGSG

              Please indicate the UEN number and/ or applicant's name under Beneficiary Reference/ Purpose of Payment/ Remittance Information/ Payment Details field to avoid delay in the processing of the application.

               

               

              Contact Information

              Arrangement that involves

              Contact number

              Individual income tax

              (+65) 6351 3090

              Corporate income tax

              (+65) 6351 3367