On or about 14 February 2019, the Inland Revenue Authority of Singapore (IRAS) has published the third edition of e-Tax Guide: Tax Deductibility of General Insurers Reserves Against Incurred But Note Reported Claims (IBNR Claims). It replaces the second edition which was published on 13 December 2007.
Under Singapore tax law, expenses are deductible for tax purposes if they are wholly and exclusively incurred in the production of income. Reserves provided for IBNR claims by general insurance companies were considered not deductible as they are not expenses which have been incurred in the production of income at the time the reserves created are claimed as a deduction. The amount of such reserves do not reflect the actual expenses or liabilities but are only estimates of contingent liabilities.
This e-tax guide (practice note) set out the guidelines in determining acceptable methodologies for estimating the liability which can be used to quantify the reserves to be allowed a deduction for tax purposes. It is also to set out the substitute methods which may be used to derive an indication of what could be a reasonable level of reserves for IBNR claims which is acceptable for tax deduction purposes.
This e-tax guide has inserted footnote 1 in Annex 1, which states that “This is applicable to a non-captive general insurance business where its policy liabilities are not required to be assessed and certified by an actuary approved by Monetary Authority of Singapore (MAS) under section 37(1)(b) of Insurance Act (Cap 142).”
Source: IRAS, 14 February 2019