Singapore: Fee rules | Research Credit Integrity Alliance

This page sets out what statute and IRAS guidance say about the fees advisers charge for Singapore research and development (R&D) and Enterprise Innovation Scheme (EIS) claims. Professional body rules on fees are covered separately on Professional body rules. This page describes the rules only and makes no recommendation.

Summary

Question	Position as at 11 October 2026	Source
Does statute cap or prohibit contingent fees for R&D or EIS claim work?	No such provision was identified for this page	See below
Must a claim disclose the adviser's fee to IRAS?	The R&D Claim Form and the Form C-S reviewer field do not ask for it	R&D Claim Form;1 Form C-S notes2
Who receives an EIS cash payout?	The business, by credit to its own GIRO bank account or by PayNow	IRAS EIS page3
Can a person who helps another obtain a payout wrongly be punished?	Yes, under section 37S of the Income Tax Act 1947	Section 37S(3) and (4)4
Is there a specific offence for promoters?	Yes for the former PIC scheme (section 37L); no equivalent EIS section was identified	Section 37L5

Is there a statutory rule on contingent fees?

No provision of the Income Tax Act 1947 or of IRAS guidance that caps, prohibits or requires disclosure to IRAS of contingent fees for preparing R&D or EIS claims was identified for this page. The R&D Claim Form asks for project details, expenditure and a technical contact person, and is declared by an authorized person of the company. It does not ask who prepared the claim or how that person is paid.1 The Form C-S asks for the name and, where relevant, the SCTP membership number of the person who reviewed the return, but not for any fee.2

Payment of the cash payout

An eligible business may elect to convert up to $100,000 of qualifying expenditure a year into a cash payout at 20 percent, in place of deductions.6 IRAS disburses the payout by direct credit to the business's GIRO bank account that is linked to pay Income Tax or GST, or through PayNow Corporate, or PayNow NRIC or FIN for sole proprietors and individuals.3

IRAS describes the payout as not taxable and states that it may be used for any purpose.6 Before paying, the Comptroller reduces the payout by any tax, duty, interest or penalty the business owes under the Income Tax Act, the Goods and Services Tax Act, the Property Tax Act or the Stamp Duties Act.7 Since 8 December 2025, the payout is also reduced by any amount the business owes IRAS from an earlier payout that is recoverable as a debt.7

The official sources reviewed for this page do not address whether a business may assign or direct the payout to a third party such as an adviser.

Offences that reach people who assist

Section 37S of the Act creates offences for false information given in an EIS cash payout election. Several of them extend expressly to a person who acts to help someone else:

Wilful false information. Anyone who willfully, with intent to obtain "or to assist another person to obtain" a payout or a higher payout that is not due, gives false information or a false answer to the Comptroller on conviction must pay a penalty of three times the payout involved, and is also liable to a fine of up to $10,000 or imprisonment of up to three years, or both.4
False records or fraud. Anyone who, with the same intent, prepares or maintains false books or records, or makes use of "any fraud, art or contrivance", on conviction must pay a penalty of four times the payout involved, and is also liable to a fine of up to $50,000 or imprisonment of up to five years, or both.4

Where false information is proved to have been given "by or on behalf of any person", the person who gave it is presumed, unless the contrary is proved, to have intended to obtain or to help obtain the payout.4 The general tax evasion offences in sections 96 and 96A are framed in the same way and cover anyone who acts to "assist any other person to evade tax".8

IRAS states in its framework for working with tax agents that it "will not hesitate to take action against errant tax agents or accountants" who provide objectionable tax advice, and that heavy penalties will be imposed for assisting others to defraud the Government.9

Lessons recorded from the PIC scheme

The Productivity and Innovation Credit (PIC) scheme allowed a cash payout in place of deductions for expenditure incurred in YA 2011 to YA 2018.10 Amendments made by Act 37 of 2014 added provisions aimed at abuse of that scheme:

Abusive arrangements. Section 37K lets the Comptroller disallow or recover PIC benefits arising from an abusive PIC arrangement. An arrangement is abusive if, for example, it uses artificial, contrived or fraudulent steps, or results in consideration greater than the open market value without a bona fide commercial reason. The section applies to arrangements made on or after 27 November 2014.11
Promoters. Section 37L makes it an offence to promote a PIC arrangement knowing or having reasonable grounds to believe it is abusive, with a fine of up to $10,000 or imprisonment of up to three years, or both. Promoting includes designing, facilitating, organizing or managing the arrangement.5

Sections 37K and 37L apply only to the PIC scheme. The table of contents of the Act lists sections 37R and 37S for the EIS cash payout and no EIS section equivalent to section 37L.12

IRAS has described how fraudulent PIC claims worked. In a 2018 news release it stated that a promoter might provide false supporting documents and the particulars of unrelated persons to meet the three local employee condition, and that "in return for facilitating the false PIC claims, the PIC promoter may take a cut from the PIC cash pay-outs given to the claimants."13 The release concerned a criminal conviction for fraud. It does not describe how advisers are paid for legitimate claims.

Fees paid to R&D organizations

A separate rule concerns payments for R&D work itself, not fees for preparing a claim. Where a business pays an R&D organization to carry out qualifying R&D in Singapore on its behalf, 60 percent of the fees may be treated as qualifying expenditure for the additional and EIS deductions, or the actual qualifying costs if the business can show they exceed 60 percent.14 A business claiming more than 60 percent must support its claim with invoices from the R&D organization.15

Sources

Inland Revenue Authority of Singapore, Research and Development (R&D) Claim Form (YA 2019 and onwards), Parts 3 to 6, including Part 4 "Declaration" and item 5O. https://www.iras.gov.sg/docs/default-source/uploadedfiles/pdf/rnd-claim-form-(ya-2019-n-after).pdf?sfvrsn=72929970_40 (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Explanatory Notes to Form C-S for Year of Assessment (YA) 2026, section "Particulars of Person who Reviewed the Return". https://www.iras.gov.sg/docs/default-source/uploadedfiles/pdf/explanatory-notes-to-ya-2026-form-c-s.pdf?sfvrsn=1d2386c1_20 (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Enterprise Innovation Scheme (EIS) (last updated 23 September 2026), section "When will I receive the EIS Cash Payout". https://www.iras.gov.sg/schemes/disbursement-schemes/enterprise-innovation-scheme-(eis) (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 37S(3), (4), (6) and (7). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr37S- (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 37L(1) and (2). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr37L- (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Enterprise Innovation Scheme (Third Edition, published 31 August 2026), paragraphs 5.8 and 5.9. https://www.iras.gov.sg/docs/default-source/e-tax/etaxguide_cit_enterprise-innovation-scheme.pdf?sfvrsn=3a36afd3_12 (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 37R(28) and (31A). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr37R- (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), sections 96(1) and 96A(1). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr96- (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Partnership with tax agents (last updated 27 March 2026), section "Consequences of non-compliance by tax agents". https://www.iras.gov.sg/who-we-are/what-we-do/public-engagement/partnership-with-tax-agents (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 37G(1). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr37G- (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), section 37K(1), (8), (9) and (11). https://sso.agc.gov.sg/Act/ITA1947?ProvIds=pr37K- (accessed 11 October 2026). Back
Attorney-General's Chambers, Income Tax Act 1947 (Singapore Statutes Online, current version), table of contents, Part 9. https://sso.agc.gov.sg/Act/ITA1947 (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, news release on the conviction of a promoter of fraudulent PIC claims (12 February 2018), section "PIC Promoters Abusing the PIC Scheme". https://www.iras.gov.sg/news-events/newsroom/promoter-of-pic-scam-jailed-7-months-for-fraudulent-pic-claims (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Enterprise Innovation Scheme (Third Edition, published 31 August 2026), Annex A, paragraph 2.3 and footnote 12. https://www.iras.gov.sg/docs/default-source/e-tax/etaxguide_cit_enterprise-innovation-scheme.pdf?sfvrsn=3a36afd3_12 (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, IRAS e-Tax Guide: Research and Development Tax Measures (Eighth Edition, published 30 January 2026), paragraph 11.2. 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