On 6 February 2026, the Inland Revenue Authority of Singapore (IRAS) issued the formal notice requiring companies to furnish income tax returns for the Year of Assessment (YA) 2026. Published in The Government Gazette, the notice sets out the statutory filing obligations under the Income Tax Act 1947. The deadline for lodgement is 30 November 2026.

This briefing analyses the technical requirements and highlights practical issues that companies and professional advisors should address in the coming months.

Applicability and Filing Deadline
The filing obligation applies to:

  • Singapore-incorporated companies in existence on or before 31 December 2025; and

  • Foreign companies registered with ACRA between 1 January 2025 and 31 December 2025.

The requirement crystallises where a company has commenced business—regardless of whether revenue was derived or losses incurred during the accounting periods ending in 2025. Notably, the mere act of incorporation, without formal commencement of business, may not trigger the filing obligation. However, the Comptroller’s position is that once a company is incorporated and not dormant under the Companies Act, the evidential burden rests with the taxpayer to substantiate non-commencement.

Foreign Companies: Expanded Compliance Scope
A significant technical point concerns foreign companies not registered with ACRA. Such entities are nonetheless required to file a YA 2026 return if:

  • They derived Singapore-sourced or deemed Singapore-sourced income during the basis period; and

  • Withholding tax has not been fully deducted and paid to the Comptroller.

This effectively operates as a compliance backstop. Practitioners should note that the absence of a withholding tax filing obligation does not automatically exempt the foreign company from corporate income tax filing. Where withholding tax was under-deducted or not deducted, the foreign company assumes direct filing liability.

Exclusions
Companies under winding up proceedings that commenced on or before 31 December 2025 are expressly exempted from filing. However, this exemption does not extend to companies in receivership or judicial management unless a winding up order has been granted. Liquidators should verify the commencement date of winding up to confirm whether a return is required.

Practical Implications and Areas of Risk

1. Dormant Companies and Administrative Concession
Companies that remained dormant throughout the basis period and have not commenced business are not required to file. However, many companies incorrectly assume dormancy for tax purposes. Practitioners should verify whether any administrative income, bank interest, or incidental revenue was received. Even nominal income crystallises filing obligations.

2. Estimated Assessments and Late Filing Penalties
Companies that fail to file by 30 November 2026 risk having estimated assessments issued under Section 37 of the Income Tax Act. Estimated assessments are often raised conservatively and may impute taxable income even where losses were incurred. Reopening such assessments requires formal objection and supporting documentation—a time-consuming process.

3. Loss-Bearing Companies and Filing Incentives
There remains no statutory exemption from filing for loss-making companies. Filing a Nil or loss return is mandatory. Practitioners should caution clients that non-filing, even where no tax is payable, may result in composition fines and prejudice loss-carry-forward claims.

4. Basis Period Alignment
YA 2026 is based on income derived in the financial year ending in 2025. Companies with accounting periods not coterminous with the calendar year should verify that the correct financial statements are mapped to the correct YA. Mismatches remain a frequent audit query.

5. Withholding Tax and Foreign Entity Filing
For foreign companies with Singapore customers, the onus is often incorrectly placed solely on the customer to withhold tax. Where a foreign company receives gross consideration and withholding tax was short-deducted, the foreign entity remains contingently liable. Proactive filing may mitigate penalty exposure.

Action Points

  • Commence collation of financial statements for the accounting period ended in 2025.

  • Confirm the commencement date of business—do not assume dormancy.

  • For foreign companies with Singapore income streams, review withholding tax deduction histories.

  • Update board and management calendars to reflect the 30 November 2026 deadline.

Conclusion
The YA 2026 notice reinforces IRAS’s broad capture of corporate entities with economic activity in Singapore. The extension of filing obligations to certain unregistered foreign companies signals continued vigilance on cross-border income reporting. Practitioners should advise clients to adopt a conservative approach to filing eligibility and prioritise timely submission to avoid estimated assessments and penalties.

Source: The Government Gazette, 6 February 2026.