What you need to know
Providing complete information helps to understand and review your request more efficiently. This webpage explains what to include in your request. You do not need to follow a prescribed format, as long as the information is clearly presented.
These guidelines also apply to requests submitted under voluntary compliance initiatives. For more details, refer to the IRAS webpages on the Assisted Compliance Assurance Programme (ACAP) and Assisted Self-help Kit (ASK).
What to include in the request
You should include the following information in your request for technical clarification.
Taxpayer's details
The taxpayer is the person you are submitting the request for. This is usually the person making or receiving the supplies covered in the request, such as the transferor, supplier, customer, or government agency.
If you represent more than one taxpayer, provide the following details for each taxpayer:
- Full name
- Tax reference number
If you are submitting a request on behalf of a customer about the GST treatment of a supply made to that customer, you must obtain the supplier's written consent and include it with your request.
This consent requirement does not apply to reverse charge supplies, as the recipient is responsible for determining the correct GST treatment.
Tax Agent's details
As a tax agent, you must be authorised by the taxpayer to submit the request. Please provide:
- Your full name and tax reference number (a letterhead bearing these details is acceptable)
- The name, contact number, and email address of the representative whom we can contact
Letter of Authority
A signed letter of authority from each taxpayer authorising you to act on its behalf should be included with your request. If you represent more than one taxpayer, please provide a separate letter of authority for each taxpayer.
Facts and circumstances
The full description of the business arrangement and its purpose should be included in the request. This includes:
- The full name, tax reference number, principal activities, and role of each party involved in the arrangement
- The GST profile of each party, such as whether they are a group, divisional, or single registered business, an overseas person, a fully taxable person, or a partially exempt trader, and any relevant GST scheme such as the Major Exporter Scheme
- A comprehensive description of the arrangement and the business reasons for it, including fees charged and any mark-up on cost recoveries
- The GST treatment adopted by the taxpayers in past and current GST reporting, and the proposed GST treatment, including the relevant GST provisions
- The affected accounting periods and the relevant transaction dates
If your request relates to a GST refund or relief under Section 89 or 90 of the GST Act, provide:
- The amount of tax involved for each affected accounting period
- The relevant GST provision
- The basis for the request, such as the just and equitable grounds relied upon if seeking remission under Section 89(1)
You may include a diagram if it helps us understand the arrangement. For example, the diagram may show the movement of goods, contractual relationships among the parties, or the flow of supply and direct beneficiaries.
Assumptions
Base your request on the facts of the arrangement as far as possible. If you need to make assumptions, clearly identify them and explain why they are necessary.
Issues and analysis
To help us understand the scope of your request, list and number each issue you would like us to address.
If an issue relates to earlier IRAS correspondence or guidance, please identify the relevant correspondence or guidance. This may include a publication, compliance initiative, or issue-specific mailer.
For each issue, provide your view and proposed GST treatment. Explain the reasons for your view and include:
- The relevant provisions of the GST Act and subsidiary legislation
- Relevant case laws and legal reasons supporting your interpretation of the relevant GST legislative provisions involved, where applicable
- Possible arguments that may support a different interpretation, with legal reasons and authoritative support, where applicable
Please explain how the information you have provided supports your analysis. Where applicable, refer to relevant tax principles, such as case law, GST rules, legal reasoning, and authoritative support, and explain how they apply.
If your request seeks to deviate from published conditions or guidance, or relates to the application of certain published administrative concessions, explain:
- Why you are unable to comply with the published conditions or guidance
- Why the challenges cannot be resolved
- How your proposed alternative approach eases the administrative burden without contravening GST rules
Supporting documents
Provide relevant supporting documents, including:
- Agreements, service contracts, and other relevant documents, with the relevant clauses or passages identified and highlighted
- Any documents required under the relevant e-Tax Guides
The List of Common Technical Requests sets out the information to provide for common types of technical clarification requests. This list is not exhaustive, and we may ask for more information during our review. If you have other information that may be relevant to your request, provide it even if it is not specified in the list.
If you cannot provide any relevant information, please explain why.
How to submit
If you are authorised via CorpPass for the taxpayer's GST matters, submit your request through myTax Mail on myTax Portal for added security.
Otherwise, submit your request using the online forms.
After you submit
If you wish to seek clarification on additional issues not covered in your original request, submit a separate request for those issues. Include all required information set out in the guidelines above.