On or about 19 November 2019, the Inland Revenue Authority of Singapore (IRAS) has also updated their bank account details for payments made from 18 November 2019 onward. The Application Form for Income Tax Advance Ruling has been revised, the form is to be used for the submission of income tax advance ruling applications with effect from 11 November 2019.
The IRAS has stated that, in order to obtain an advance ruling, a business is required to submit an application form along with the required fees and provide details of the arrangement.
The IRAS has further explained that businesses have to submit the following before the date of the proposed arrangement:
- Application form for income tax advance ruling.
- A written ruling request providing:
- 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;
- the issue(s) to be considered;
- 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;
- 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
- a draft ruling.
- Full particulars of the arrangement in question comprising:
To enable the IRAS to expedite the review of advance ruling request, a business will need to submit additional information if the arrangement involves Sale of property or Sale of shares. As the matter on which the ruling is sought would require the IRAS to determine a question of fact, they may, at their discretion, decline to make a ruling after reviewing the additional information submitted.
For more information, please visit the IRAS website.
Source: IRAS website, 19 November 2019.