Advance ruling system for Singapore income tax made simple

  • June 08, 2025

Singapore advance rulling system

 

Confused about how advance rulings work in Singapore tax law? You’re not alone.

But understanding—and using—the advance ruling system can give you a huge advantage.

ACE has helped multiple businesses get certainty on their tax treatment before filing.

One clear decision? A client avoided a six-figure tax risk thanks to a well-structured ruling request.

Uncertainty in tax can cost you. And relying on assumptions could lead to penalties or audits down the road.

Why take that chance?

In this guide, we’ll break down how the advance ruling system works in Singapore. So you can make informed decisions, gain peace of mind, and maintain a solid tax position.

What is the Advance Ruling System in Singapore?

You can think os it as asking IRAS for a “yes or no” before making a tax move.

The advance ruling system lets you get written clarification from the Inland Revenue Authority of Singapore (IRAS) on how tax law applies to a specific arrangement or transaction, before you carry it out.

In other words, no guessing. No crossing fingers.

You submit your case. IRAS reviews it. And you get a binding reply on how the tax rules apply.

Here’s the key:
Once IRAS issues a ruling, it must follow it, as long as the facts don’t change and you fully disclose everything.

That’s why large corporations and savvy startups use advance rulings. They want certainty. They want to avoid tax surprises. And they want legal backup when facing complex tax decisions, like transfer pricing, restructuring, or cross-border deals.

But advance rulings aren’t for everyday questions.

They’re best for complex, high-stakes, or grey-area tax issues where the law could go either way.

In the next section, we’ll walk you through how to apply—and how to know if it’s worth it for your business.

Scope of the Advance Ruling (And when IRAS might say no)

Advance rulings sound powerful, and they are.

But they’re not a blanket pass for everything tax-related.

An advance ruling only applies to:

  • The specific applicant
  • The exact arrangement described in the request
  • The year(s) and Income Tax Act provisions mentioned in the ruling

And most importantly:

It binds IRAS, not you. So if they rule a certain tax treatment applies, they’re required to honor it—as long as your facts don’t change.

But don’t assume IRAS will rule on just anything.

There are situations where IRAS will not issue a ruling. For example:

  • You’re asking about foreign tax laws or double tax agreements
  • You’re requesting IRAS to judge an accounting principle or a commercial practice
  • IRAS has already assessed the arrangement for that Year of Assessment
  • IRAS has started an audit or investigation on the matter
  • The request is frivolous, not serious, or lacks enough information, even after follow-up

Even if your request is legitimate, IRAS might still pass on it if:

  • The matter involves subjective facts that IRAS can’t confirm
  • There’s an ongoing objection or appeal
  • The tax treatment is already clearly defined by law
  • The ruling would rely on assumptions about future events

In short, Advance rulings are for specific, complex, high-impact questions, not for simple clarifications or hypothetical scenarios.

How to apply for an Advance Ruling in Singapore?

Getting clarity from IRAS starts with one thing: a formal request.

To apply, you’ll need to fill out a form, pay a fee, and provide a detailed breakdown of your proposed arrangement.

Let’s walk through what’s needed.

Who can apply?

  1. Single applicant: You can apply in your own name, or even on behalf of an entity that hasn’t been legally formed yet.
  2. Joint applicants: Two or more parties can apply together.
  3. Authorised agent: Your tax agent can file the request, but only if you give written consent (fill out Section E of the official form).

What to submit

Here’s your must-have checklist before IRAS will even look at your application:

Application form

You can download the form via this link: Application form for advance tax ruling  for income tax.

A written ruling request with:

  1. Full description of your proposed arrangement
  2. Who’s involved + their background
  3. Business purpose of the arrangement (if applicable)
  4. Copies of any relevant contracts or documents
  5. Key tax issue(s) you want IRAS to clarify
  6. Relevant sections of the Income Tax Act 1947
  7. Legal reasoning, case law (if any), and opposing arguments (if any)
  8. Whether you’ve submitted a similar request before, and the outcome
  9. A draft ruling (yes, IRAS wants your proposed wording)

Tip: If your arrangement involves the sale of property or shares, submit the extra forms. But note: IRAS can still decline if they feel it boils down to a “question of fact.”

When you apply for an advance ruling, you have to pay the application fee of S$660. 

You will be charged an hourly rate of S$165 (inclusive of GST) for each hour or part thereof after the first 4 hours taken to provide the ruling.

What happens after you apply?

Once IRAS reviews your request, they’ll let you know whether your application is accepted and what to expect next.

If your application is accepted

Good news: You’re in.

Here’s what happens next:

  1. IRAS will tell you the estimated total cost (including any time-based or express fees).
  2. You’ll need to confirm in writing that you accept their terms before they proceed.
  3. Standard rulings: Usually issued within 8 weeks after all required information is received.
  4. Section 10L (economic substance) rulings: Fast-tracked—about 4 weeks.
  5. If it’s a complex case, IRAS will let you know if they need more time.

If your application is not accepted

IRAS will inform you, and explain why. But note: the S$660 application fee is non-refundable, even if your request is rejected.

What to do when you need to withdraw the application?

You can withdraw your advance ruling request anytime before IRAS issues the ruling.

But timing matters—especially when it comes to fees.

If you withdraw before accepting the IRAS term

  • You pay only the application fee (S$660).
  • No refunds. No extra charges.
  • Just send a written notice and you’re out.

If you withdraw after accepting the IRAS term

Things get pricier.

  1. You’ll still pay the S$660 application fee plus:
  2. A time-based fee for IRAS’s work so far
  3. An express fee (if you asked for a fast-track ruling)
  4. Any reimbursement costs (e.g., for external advice or resources)

If you need to learn more and receive professional support on how to do your application for advance ruling,

You may contact IRAS  for assistance or clarification on the advance ruling system for income tax

Arrangement that involves Contact details
Individual Income Tax IIT_RC@iras.gov.sg
Corporate Income Tax CTRuling@iras.gov.sg

If your company needs help filing taxes for the year 2025 or requires assistance with Singapore incorporation, economy, banking, etc., feel free to call /WhatsApp us at +65 90612851 or email us at aceglobalacct@gmail.com. Alternatively, you may leave us a reply using our contact form below.

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