If your company’s Notice of Assessment from IRAS looks wrong, first check which type of notice it is, because only some types need an objection. For corporate income tax, IRAS says an estimated assessment raised because the company did not file, and a completed assessment, both require an objection within 2 months if you disagree, made through Revise/Object to Assessment on myTax Portal. The tax shown must still be paid within 1 month of the notice, even while the objection is pending; any excess is refunded. For GST, an objection to an assessment must be made within 30 days of the notice. Missing these deadlines usually leaves the assessment standing.
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The objection deadline is the chance to correct the assessment. Two months for corporate tax and 30 days for GST pass quickly, and IRAS will not revise an estimated assessment unless the full return, accounts and tax computation come with the objection. Act as soon as the notice arrives, pay what is shown, and object properly with the documents.
Which type of notice is it?
IRAS’s page on what happens after filing Form C-S or Form C sets out four types:
| Type | What it is | Objection needed if you disagree? |
|---|---|---|
| Type 1 | Based on the Estimated Chargeable Income (ECI) the company filed | No |
| Type 2 | Estimated by IRAS because the company did not file ECI or its Form C-S/C on time, declared a low ECI, or for an advance assessment | Yes, within 2 months |
| Type 3 | Estimated by IRAS from the filed Form C-S/C, pending review | No |
| Type 4 | Completed assessment, per the return filed or with IRAS adjustments | Yes, within 2 months |
The message printed on the notice tells you which type it is. A Type 4 with adjustments is the most common reason a company thinks its notice “looks wrong”: IRAS may have disallowed an expense, a capital allowance or a loss carried forward.
Common reasons the figures differ
- Estimated because a return was late. File the Form C-S or Form C with the accounts and tax computation, and object. IRAS says the estimate will not be revised otherwise.
- IRAS adjusted the return after a review. Read the adjustment letter, and check each item against the tax computation and supporting documents.
- Losses or capital allowances not carried forward as expected, for example because the shareholding test was not met or an earlier assessment was not finalised.
- A filing error by the company rather than IRAS. That is not an objection point in the same way; see the error-relief section below.
How to object to a corporate tax assessment
- Note the date of the notice and diarise 2 months from it.
- Pay the tax shown within 1 month. IRAS’s examples show that a 5% late payment penalty is imposed if the tax is not paid by the due date, even when an objection is pending; it is revised if the assessment is reduced.
- Prepare the grounds: what is wrong, the correct figure, and the computation and documents that support it.
- Object through myTax Portal using Revise/Object to Assessment, through an authorised Corppass user.
- Answer IRAS’s follow-up questions promptly and keep copies of everything.
Errors the company made itself
If the company’s own return contained a mistake that led to too much tax, IRAS explains that relief for errors or mistakes may be claimed under section 93A of the Income Tax Act, subject to conditions, by applying in writing no later than 4 years after the end of the Year of Assessment in which the assessment was made. If the mistake meant too little tax, the right route is a voluntary disclosure. See IRAS voluntary disclosure.
GST assessments
IRAS’s page on objecting to GST decisions says an objection must be in writing to the Comptroller of GST, state detailed reasons, be signed and dated, and for an assessment be made within 30 days of the notice. If you disagree with the decision on the objection, you can appeal to the GST Board of Review within 30 days, then lodge a petition of appeal within a further 30 days; the burden is on you to prove the decision is wrong. An estimated GST assessment for a missed return is different: file the return. See overdue GST returns.
How long IRAS can go back
IRAS states that the time limit for it to raise an assessment or additional assessment is 4 years, and that the limit does not apply where fraud is involved. Keep the records behind each year’s return for at least that long, and longer where the law requires.
Frequently asked questions
We missed the 2-month deadline. What now?
Speak to IRAS and a tax adviser quickly. Depending on the facts, there may still be options, but do not assume a late objection will be accepted. See also IRAS estimated assessments based on bank records.
Do we have to pay if we think the assessment is wrong?
Yes. IRAS says the tax must be paid even if you intend to object or are waiting for the outcome. Excess tax is refunded if the assessment is revised.
Can our tax agent object for us?
Yes, if the agent is authorised through Corppass to act for the company on myTax Portal.
More on the tax and GST hub.
Notice of Assessment looks wrong?
If your company has received a Notice of Assessment it does not agree with, contact the Raffles Corporate Services team at [email protected] or on WhatsApp at +65 8501 7133. We will review the notice against the tax computation, prepare any outstanding return, and draft and file the objection with the supporting documents. Where a dispute needs a tax adviser or an adviser from one of our associated law firms, we will arrange it. This article is general information, not tax advice.
Kevin Yeo, Raffles Corporate Services