Singapore: Disputes and appeals | Research Credit Integrity Alliance

This page explains how a company in Singapore can challenge IRAS when it reduces or disallows a research and development (R&D) deduction or an Enterprise Innovation Scheme (EIS) claim. It describes the rules only and makes no recommendation.

Summary

Step	Time limit	Source
Ask for referral to IRAS's Technical Advisory Panel on R&D questions	During IRAS's review	R&D e-Tax Guide1
File a notice of objection with precise grounds	2 months from the date of service of the notice of assessment, for companies	Income Tax Act 1947, section 76(3)2
Reply to IRAS's decision on the objection	3 months from the date of IRAS's letter, unless another date is given	Objection e-Tax Guide3
Lodge a notice of appeal to the Income Tax Board of Review	30 days after the Comptroller's refusal to amend	Section 79(1)(a)4
Lodge a petition of appeal	30 days after the notice of appeal	Section 79(1)(b)4
Appeal to the General Division of the High Court	On a question of law, or of mixed law and fact, where the tax exceeds $200	Section 81(2)5

Before an assessment: the Technical Advisory Panel

Whether a project qualifies as R&D depends partly on technical requirements: the project must have a qualifying objective, involve novelty or technical risk, and involve a systematic, investigative and experimental study.6 IRAS has a Technical Advisory Panel to advise it on R&D claims. A case may be referred to the Panel if the taxpayer asks for a referral, or if IRAS rejects the claim after two rounds of review and the taxpayer wishes to pursue it.1 IRAS describes a meeting with the Panel as "solely for clarifications on R&D claims" and "not an arbitration session". IRAS makes the final decision with the Panel's technical advice.7 Once IRAS has informed the taxpayer of its decision, a taxpayer who disagrees can object to the assessment through the normal objection and appeal process.1

Objection

A person who disputes an assessment may apply to the Comptroller, by written notice of objection, to review and revise it.2 For a company, the notice must be made within two months from the date of service of the notice of assessment, and must state precisely the grounds of objection.2 The Comptroller must extend the period where absence, sickness or other reasonable cause prevented the objection being made in time.2

IRAS's guidance says a valid objection should contain the Year of Assessment, a description of each item, the amount, and the reason why the deduction should be allowed. An objection that says only that the assessment is "excessive" is generally not valid.8 Objections are filed through the "Revise/ Object to Assessment" digital service, by form or by letter.8 IRAS states that it plans to require all companies to use the digital service from 1 July 2027, and that the change will be included in the Finance (Income Taxes) Bill 2026.9

Where an objection is made to an amended assessment, the right to object is limited to the amendment and matters relating to it.2 The tax in the notice of assessment must still be paid within one month, whatever the objection.9

IRAS's review and decision

IRAS aims to give its decision in writing within six months of receiving the taxpayer's last correspondence with complete information.3 The taxpayer must then say in writing, usually within three months, whether it agrees. If the parties agree, the assessment is amended. If they do not, the Comptroller gives a notice of refusal to amend.3 IRAS may also issue that notice if requested information is still outstanding two years after the objection, if the taxpayer does not reply, or if the taxpayer's agreement is qualified.3

Appeal to the Income Tax Board of Review

A person aggrieved by an assessment who has failed to agree with the Comptroller may appeal to the Income Tax Board of Review. A notice of appeal must be lodged within 30 days after the Comptroller's refusal to amend, and a petition of appeal with the grounds within 30 days after that.4 The Board's chairperson may allow a late appeal in cases of absence, sickness or other reasonable cause.4 At the hearing, the appellant may not rely on grounds other than those in its petition without the Board's consent.4

Appeals to the courts

The Board's decision is final except as the Act provides. Where the tax at stake exceeds $200, either side may appeal to the General Division of the High Court on a question of law or of mixed law and fact.5 Further appeals lie as for other decisions of the General Division of the High Court.5

R&D deductions have been litigated through this route. In [2020] SGHC 218, the High Court heard an appeal against a decision of the Board that had affirmed the Comptroller's disallowance of deductions for R&D payments made under a cost-sharing agreement. The Court held that the payments did not fall within the provision then relied on and dismissed the appeal.10 The case concerned the law before amendments that now provide separately for cost-sharing payments.10

Relief for errors made by the company

A company that finds an error in its own return may apply in writing for relief within four years after the end of the Year of Assessment in which the assessment was made, under section 93A of the Act.11 Where the return was made on the basis of, or in accordance with, the Comptroller's practice generally prevailing at the time, no relief by repayment of tax is given for an error or mistake as to the basis on which the liability ought to have been computed, and no amendment may be made to the assessment under that section.12 For corporate tax, voluntary disclosures of errors are made through the same "Revise/ Object to Assessment" digital service.13 See Voluntary disclosure programme.

EIS cash payouts

IRAS states that a company that has claimed enhanced deductions on expenditure it also elected to convert into cash should make the amendments through the "Object to Assessment" digital service.14 Where IRAS recovers a cash payout, it issues a recovery notice and the business must repay within 30 days.15 The official sources reviewed for this page do not say whether a decision to refuse or recover an EIS cash payout can itself be challenged by objection and appeal under sections 76 and 79.

Sources

Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Research and Development Tax Measures (Eighth Edition, published 30 January 2026), paragraphs 13.2 to 13.5 and 13.7. https://www.iras.gov.sg/docs/default-source/e-tax/research-and-development-tax-measures-etax-guide_6th-edition.pdf?sfvrsn=1f38a2e8_27 (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 76(2), (2A), (3) and (4). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr76- (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Corporate Income Tax: Objection and Appeal Process (Fourth Edition, published 30 January 2026), paragraphs 2.3 to 2.5 and 5.1 to 5.4. https://www.iras.gov.sg/media/docs/default-source/e-tax/e-tax-guide_cit_objection-and-appeal-process.pdf?sfvrsn=83675467_11 (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 79(1), (3), (11) and (12). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr79- (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 81(1), (2) and (5). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr81- (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Research & Development (R&D) Tax Measures (last updated 13 August 2026), section "Qualifying R&D Projects". https://www.iras.gov.sg/taxes/corporate-income-tax/income-deductions-for-companies/business-expenses/research-development-(r-d)-tax-measures (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Research & Development (R&D) Tax Measures (last updated 13 August 2026), section "Technical Advisory Panel". https://www.iras.gov.sg/taxes/corporate-income-tax/income-deductions-for-companies/business-expenses/research-development-(r-d)-tax-measures (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Corporate Income Tax: Objection and Appeal Process (Fourth Edition, published 30 January 2026), paragraphs 4.3 to 4.5. https://www.iras.gov.sg/media/docs/default-source/e-tax/e-tax-guide_cit_objection-and-appeal-process.pdf?sfvrsn=83675467_11 (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, After Filing Form C-S/ Form C-S (Lite)/ Form C (last updated 29 May 2026), section "Objecting to the Notice of Assessment". https://www.iras.gov.sg/taxes/corporate-income-tax/form-c-s-form-c-s-(lite)-form-c-filing/after-filing-form-c-s-form-c-s-(lite)-form-c (accessed 11 October 2026). Back
High Court of the Republic of Singapore, [2020] SGHC 218, Tax Appeal No 3 of 2020, paragraphs 1, 7, 13, 22 and 29. https://www.elitigation.sg/gd/s/2020_SGHC_218 (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 93A(1). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr93A- (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 93A(3) and (3A). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr93A- (accessed 17 October 2026). Back
Inland Revenue Authority of Singapore, Voluntary disclosure of errors for reduced penalties (last updated 21 May 2026), section "Making a voluntary disclosure". https://www.iras.gov.sg/taxes/corporate-income-tax/corporate-income-tax-compliance/voluntary-disclosure-of-errors-for-reduced-penalties (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Enterprise Innovation Scheme (EIS) (last updated 23 September 2026), section "How to amend my online EIS application after submission". https://www.iras.gov.sg/schemes/disbursement-schemes/enterprise-innovation-scheme-(eis) (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Enterprise Innovation Scheme (Third Edition, published 31 August 2026), paragraph 6.14. https://www.iras.gov.sg/docs/default-source/e-tax/etaxguide_cit_enterprise-innovation-scheme.pdf?sfvrsn=3a36afd3_12 (accessed 11 October 2026). Back