IRAS issues e-Tax Guides and updates on our website to set out our views on the tax treatment of general tax issues. 

Where useful or appropriate, IRAS will include examples modified from advance rulings in the e-Tax Guides and on our website, to provide greater tax certainty and transparency on IRAS interpretation of tax laws. You may wish to refer to these publications before making an advance ruling application. 

To enhance taxpayers’ understanding of IRAS’ interpretation and application of tax laws in specific scenarios, we will be publishing a summary of advance rulings applied for on or after 1 May 2019, in the manner outlined below.

Publication of Advance Rulings

We will publish a summary of the ruling (i.e. a summary of the background, facts and issues raised in the application for advance ruling, as well as the rulings given) on the IRAS website in respect of advance ruling applications made on or after 1 May 2019, if: 

a.   you have given your consent for the publication of a summary of the ruling in Section D of the advance ruling application form; and

b.   the issue that is the subject of the ruling request does not relate to Advance Pricing Arrangements. 

The summary of the ruling will be published in a form that does not set out the identity of the applicant, the arrangement or any other parties to the arrangement in the ruling, date of transactions or transaction values. Please refer to the Sample Format of an Advance Ruling that will be published.

Timeline for Publication of Advance Rulings (wef 1 May 2019)

A summary of the ruling will be published on our website at least six months after the ruling has been issued.

Prior to publication, we will provide you with a draft copy of the summary of the ruling for your comments within eight weeks from the date of the ruling letter. You must review the draft summary carefully and notify IRAS of any proposed edits (with reasons) within six weeks. We will consider any comments and proposed changes made by you before the publication of the summary.  No fee is chargeable for the time spent in preparing the summary of the ruling for publication.

The expected timeline for the publication of advance ruling is as follows:

Activity Remarks
 1. IRAS issues ruling to applicant 
 2. IRAS sends first summary of ruling to applicant for review and agreement Within eight weeks from date of ruling letter
 3. Applicant to reply to IRAS with proposed edits and reasons for the edits, or confirmation that no edit is required Within six weeks from the date IRAS sends the first summary [1] [2]
 4. IRAS sends second summary of ruling to applicant for review and agreement Within six weeks from the receipt of applicant’s reply on the first summary
 5. Applicant to reply to IRAS with proposed edits and reasons for the edits, or confirmation that no edit is required Within six weeks from the date IRAS sends the second summary [1] [2]
 6. IRAS uploads the  summary of ruling on IRAS websiteAt least six months after the ruling is issued to the applicant

[1] If a reply is not received by the timeline mentioned, IRAS may proceed to upload the ruling summary on IRAS website after six months from the date of the ruling.
[2] IRAS may consider request for extension of time to reply on the summary on a case-by-case basis, such extensions to be requested for at least one week before the original deadline lapses. 

 

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