The Income Tax (Refundable Investment Credits) Regulations 2025 have been amended with effect from 1 April 2026. Concurrently, two Assignment of Functions notifications under section 3A of the Income Tax Act 1947 have been issued to enhance the administrative powers of the Economic Development Board (EDB) and Enterprise Singapore Board (ESG) in relation to the Refundable Investment Credits (RIC) scheme.
Key Technical Amendments to the RIC Regulations
1. Amendment of Letter of Confirmation (Section 93B(20A))
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The Regulations now prescribe the specific circumstances under which a letter of confirmation may be amended.
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Practical impact: Entities holding RICs must reassess whether any changes in qualifying conditions, project scope, or timelines trigger an amendment requirement. Failure to apply for amendment where prescribed circumstances exist may jeopardise credit validity.
2. Transfer of RICs in an Amalgamation (Section 93B(43)(c))
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A prescribed period is introduced within which an amalgamated company must apply to the approving authority for the transfer of RICs.
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Practical impact: In corporate restructuring via amalgamation, strict time limits now apply. Late applications may result in forfeiture of unutilised RICs. Tax teams must integrate RIC transfer timelines into merger integration plans.
3. Offset of Due Taxes – Related Company (Section 93B(48D))
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The prescribed date for the purpose of offsetting due taxes of a related company has been specified.
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Practical issue: The effective date for determining eligibility and computation of offset must be tracked precisely. Related companies should align their tax payment schedules and filing timelines to avoid mismatches in offset claims.
4. Method of Application for Offset of Due Taxes
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A standardised method of application for offsetting due taxes of a related company is now set out.
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Practical impact: Previously informal or varied submission practices are no longer acceptable. Accountants must implement the prescribed application format and supporting documentation requirements to avoid rejection or delay.
Administrative Notifications – Enhanced Powers for EDB and ESG
- Income Tax (Assignment of Functions under Section 3A — Economic Development Board) (Amendment) Notification 2026
- Income Tax (Assignment of Functions under Section 3A — Enterprise Singapore Board) (Amendment) Notification 2026
Both notifications provide additional powers to the respective Boards in administering the RIC scheme.
Practical implications for practitioners:
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EDB and ESG now have expanded authority to request information, verify compliance, and potentially adjust or revoke RICs where conditions are not met.
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Taxpayers must maintain robust supporting documentation for RIC claims, as audit and enforcement capabilities have been strengthened.
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Engagement letters with RIC applicants should explicitly acknowledge these Boards’ enhanced oversight roles.
Recommended Actions
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Review existing RIC approvals and letters of confirmation to determine if any prescribed circumstances for amendment have arisen.
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Update internal checklists to include the new prescribed period for RIC transfers in amalgamations.
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Revise tax payment and offset procedures to align with the prescribed date and application method for related-company offsets.
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Inform clients of the expanded administrative powers of EDB and ESG, and advise on documentary retention policies.
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Monitor further guidance from the Inland Revenue Authority of Singapore and the Boards on transitional arrangements for applications in progress before 1 April 2026.
Source: Government Gazette, 1 April 2026