If your company misses the 30 November deadline for its Form C-S, Form C-S (Lite) or Form C, the return can still be filed, and it should be filed as soon as possible. Late filing is an offence under the Income Tax Act 1947. IRAS may issue an estimated Notice of Assessment, offer to compound the offence for up to $5,000, send a notice to a director, and ultimately summon the company or its directors to court. The way out is the same at every stage: file the outstanding return, pay what is billed on time, and deal with each notice by its own due date.
Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.
For Year of Assessment (YA) 2026, IRAS requires every company to file by 30 November 2026, unless it has been granted a waiver. This guide is for directors who are about to miss that date, or already have.
Is it too late to file after 30 November?
No. IRAS’s own guidance on late filing tells companies to e-file the outstanding return through myTax Portal, and filing is what stops most of the follow-up action. The person filing must be authorised for the company’s corporate tax e-services through Corppass.
Check which return applies, because the paperwork differs. IRAS says Form C-S is for Singapore-incorporated companies with annual revenue of $5 million or below that meet its other conditions, and Form C-S (Lite) is for those that qualify for Form C-S and have revenue of $200,000 or below. A company filing Form C-S or Form C-S (Lite) does not submit its financial statements and tax computation with the return, but must prepare them and produce them if IRAS asks. A Form C filer must submit the financial statements, tax computation and supporting schedules with the return. Our comparison of Form C-S, Form C-S (Lite) and Form C explains the qualifying conditions.
A dormant company is not excused either. IRAS says it must e-file the Form for Dormant Company unless it has been granted a waiver of the corporate income tax return. Our dormant company guide covers when a waiver may be available.
What can IRAS do after the deadline passes?
IRAS lists four recovery actions for late or non-filing, and more than one can run at the same time.
| IRAS action | What it means | What the company should do |
|---|---|---|
| Estimated Notice of Assessment | IRAS estimates the tax from previous years’ income or other information, and may assume income has increased | Pay within 1 month of the notice date. To correct it, file the return with the financial statements and tax computation within 2 months of the notice date |
| Offer of composition | An offer to settle the offence instead of prosecution, of up to $5,000 per offence depending on past compliance | Pay the composition and file the overdue return and documents by the due date in the offer |
| Notice to a director under section 65B(3) | The director is required to provide the information IRAS specifies by a due date | Provide the information by the due date. Failure may lead to a summons |
| Notice to Attend Court or Summons | Issued to the company or those running it, including directors, where the return, documents or composition payment are not received in time | File the return and pay the composition by the deadline in the notice, or attend court on the date stated |
On conviction, IRAS states that the company faces a fine of up to $5,000 per offence, and a director convicted of failing to comply with a section 65B(3) notice faces a fine of up to $10,000, imprisonment of up to 12 months, or both, per offence. Where a company has not filed for 2 years or more, IRAS says the court may also order it to pay a penalty of twice the tax assessed for that YA, on top of a fine of up to $5,000. The return still has to be filed after any conviction.
A catch-up plan for the first weeks of December
- Check myTax Portal. Confirm whether the return shows as outstanding and whether any estimated assessment or composition offer has been issued. Note the date printed on each notice.
- Confirm the return type and the basis period. YA 2026 covers the financial year that ended in 2025. If the financial year end has changed recently, check which accounts belong to which YA.
- Finish the accounts. Unfinished accounts are usually the real cause of the delay, and ACRA deadlines are often at risk too. Our company compliance calendar shows how the ACRA and IRAS dates fit together.
- Prepare the tax computation. This is where non-deductible expenses are added back, capital allowances are claimed and any exemptions are applied. It must be ready even for Form C-S, because IRAS can ask for it.
- File the return. Do not wait for a composition offer before filing.
- Pay any estimated tax by its due date. Paying does not mean you accept the figure.
An estimated assessment has arrived: pay it, then correct it
An estimated Notice of Assessment is often the first visible sign that the deadline has been missed, and it can be much higher than the real liability because IRAS may assume income has grown. IRAS says the estimated tax must be paid within 1 month of the notice date, even if the company intends to object.
If the tax is not paid by the due date, IRAS’s late payment rules apply: a 5% penalty on the unpaid tax, and if the tax is still unpaid 60 days after that, a further 1% for each completed month, up to a maximum of 12%. Our guide to late payment penalties and payment plans covers what to do if the company cannot pay.
To correct the estimate, the company must object within 2 months of the notice date, and IRAS says the objection must come with the return, financial statements and tax computation. Without them, the estimate will not be revised. Once the documents are in, IRAS reviews the objection and refunds any excess tax paid. Our article on a Notice of Assessment that looks wrong explains the objection route on myTax Portal.
Should we pay the composition offer or appeal it?
A composition offer is IRAS giving the company the chance to settle the offence without prosecution. To avoid prosecution, both things must happen by the due date stated in the offer: the composition is paid and the overdue return and documents are filed. Paying alone is not enough. IRAS says legal action may still follow if the return is not filed, and the payment is then applied to any unpaid tax.
Quote the payment slip number. IRAS says GIRO cannot be used for a composition payment.
A waiver of the composition can be requested through the Appeal Penalty Waiver digital service on myTax Portal, not by myTax Mail, email or phone. IRAS says appeals are considered only by reference to two conditions: that the outstanding return and documents were submitted before the due date in the offer and appear in the tax account, and that the company’s returns were filed on time for the past 2 years. A company that is regularly late should not expect a waiver.
What if a summons or a director’s notice has been issued?
A Notice to Attend Court gives a court date. IRAS says the company can avoid attending by filing the outstanding return and documents and paying the composition, quoting the payment slip number, by the deadline in the notice. If more time is needed, a representative, who may be a director, must attend court on the stated date with a Letter of Authorisation to ask for a postponement. IRAS warns that not attending may lead to further legal action, which may include a warrant of arrest against the director.
A section 65B(3) notice is addressed to a director personally, and the penalties on conviction fall on the director.
Can the company ask for more time?
For the current YA, IRAS says an extension of time to file can be requested online through the Request Extension of Time to File service on myTax Portal, and that this service is only available after 30 November. Once a Notice to Attend Court or Summons has been issued, an online extension is no longer possible, and the request must be made in court. IRAS does not grant extensions for previous YAs, because those returns are long overdue.
An extension request is not a substitute for a filing plan. If the accounts are late every year, look at the bookkeeping cycle, the audit timetable or the financial year end itself.
Example: a trading company that slips past 30 November
Example: A hypothetical trading company has a 31 December financial year end. Its FY2025 accounts were delayed because a key supplier reconciliation was not finished, and on 1 December 2026 its YA 2026 Form C-S is still outstanding.
The directors finalise the accounts and the tax computation over the next week and file the Form C-S through myTax Portal. Later, IRAS issues an estimated Notice of Assessment dated before the filing had been processed, based on a higher income figure. The company pays the estimated tax within 1 month of the notice date to avoid the 5% penalty, and within 2 months lodges an objection with the return, financial statements and tax computation. IRAS reviews the objection and the excess is refunded once the assessment is revised.
Documents checklist
- Final financial statements for the financial year that forms the basis period
- Tax computation with supporting schedules, including capital allowance and non-deductible expense schedules
- Every IRAS notice received: estimated assessment, composition offer, section 65B(3) notice or summons
- Corppass authorisation for the person filing
- Payment records for any estimated tax and composition, with the payment slip number
Frequently asked questions
Does filing the return late cancel the estimated assessment automatically?
Do not assume it does. IRAS links the revision of an estimated assessment to an objection filed within 2 months of the notice, supported by the return, financial statements and tax computation. Check the notice date and lodge the objection in time.
Our company had no income this year. Do we still have to file?
Yes, unless IRAS has granted a waiver. A dormant company files the Form for Dormant Company. A company with only small amounts of income, such as bank interest, should check whether it is really dormant for tax purposes.
If we pay the composition, is the matter closed?
Only if the overdue return and documents are also filed by the due date in the offer. IRAS says legal action may still follow if the return is not filed after payment.
Can the directors be personally affected?
Yes. A summons may be issued to directors as well as the company, and a director who does not comply with a section 65B(3) notice can be fined up to $10,000, imprisoned for up to 12 months, or both, per offence.
Need help filing an overdue corporate tax return?
If your company has missed, or is about to miss, its Form C-S or Form C deadline, contact the Raffles Corporate Services team at [email protected] or on WhatsApp at +65 8501 7133. We can bring the bookkeeping up to date, prepare the financial statements and tax computation, file the return through myTax Portal, and help you respond to an estimated assessment or composition offer with the right documents.
Kevin Yeo, Raffles Corporate Services