Singapore: Professional body rules | Research Credit Integrity Alliance

This page sets out what the two main professional codes for accountants and tax professionals in Singapore say about contingent fees and related matters. Statute and IRAS guidance on fees are covered on Fee rules. This page describes the rules only and makes no recommendation.

Summary

Body	Code	Who it binds	Contingent fees
Institute of Singapore Chartered Accountants (ISCA)	Ethics Pronouncement 100, Code of Professional Conduct and Ethics, effective 1 July 2025	All ISCA members; failure to comply may lead to disciplinary action1	Allowed for non-assurance services, subject to the conceptual framework; prohibited for audit engagements and restricted for non-assurance services to audit clients2
Singapore Chartered Tax Professionals (SCTP)	Code of Ethics and Professional Conduct, effective 1 September 2026	SCTP members; failure to comply may lead to disciplinary proceedings3	The Code does not use the term; it requires disclosure of third-party commissions and recommends written fee terms4

Neither code is legislation. Each binds the members of the body that issued it.13

ISCA Code of Professional Conduct and Ethics

Scope

The ISCA Code establishes ethical requirements for ISCA members. Compliance with it is mandatory for all members, and failure to observe it may result in disciplinary action.1 ISCA first issued Ethics Pronouncement 100 on 25 November 2015. The version reviewed for this page was revised on 20 March 2025 and is effective from 1 July 2025.5

Fees and contingent fees in general

Section 330, in Part 3 of the Code on professional accountants in public practice, deals with fees and other remuneration. It states that the level and nature of fee arrangements might create a self-interest threat to compliance with the fundamental principles.6

On contingent fees, the Code says:

contingent fees are used for certain types of non-assurance services, but they might create threats to compliance with the fundamental principles, "particularly a self-interest threat to compliance with the principle of objectivity, in certain circumstances";2
factors relevant to evaluating the threat include the nature of the engagement, the range of possible fee amounts, the basis for determining the fee, disclosure of the basis of remuneration to intended users of the work, and whether an independent third party is to review the outcome;2 and
possible safeguards include having an appropriate reviewer who was not involved in the service review the work, and obtaining an advance written agreement with the client on the basis of remuneration.2

The Code defines a contingent fee as "a fee calculated on a predetermined basis relating to the outcome of a transaction or the result of the services performed by the firm". A fee established by a court or other public authority is not a contingent fee.7

Audit and assurance clients

The independence standards in the Code are stricter. A firm "shall not charge directly or indirectly a contingent fee for an audit engagement".8 A firm or network firm also may not charge a contingent fee for a non-assurance service to an audit client if the fee is material to the firm expressing the audit opinion, if it is material to a network firm that takes part in a significant part of the audit, or if the outcome of the service depends on a judgment related to the audit of a material amount in the financial statements.8 Similar requirements apply to other assurance engagements.9

Tax planning

Section 380 covers tax planning services. It does not cover services "generally referred to as tax compliance or tax preparation", which assist a client in meeting filing, reporting and payment obligations, although where a service combines planning and compliance, the planning part is covered.10 Among the examples of threats it lists, the Code states that a self-interest threat might be created when an accountant "accepts a fee that might be perceived to be excessive" for developing a tax planning arrangement where the interpretation of the law is uncertain or unclear.11

Whether preparing an R&D or EIS claim falls within tax planning or tax compliance under section 380 is not addressed in the Code.

SCTP Code of Ethics and Professional Conduct

Scope

SCTP describes itself as the national professional body for the tax community in Singapore. It was established in 2010 as the Singapore Institute of Accredited Tax Professionals and renamed in 2020.12 IRAS describes SCTP as the accreditation body for tax professionals in Singapore.13 SCTP states that its Code was launched on 1 January 2011 and that all accredited tax professionals must adhere to it.14 Failure to adhere may result in disciplinary proceedings, which may lead to removal from membership.3

What it says about fees

The SCTP Code reviewed for this page does not use the term "contingent fee". Its provisions on fees and objectivity are:

Objectivity. Relationships that create conflicts of interest or bias, or that unduly influence a member's professional judgment, "must be avoided".4
Commissions. A member "must always disclose to his client if he is receiving a commission, incentive or any other advantage from a third party relating to the matter upon which he is advising his client".4
Engagement letters. A member is strongly recommended to issue an engagement letter at the outset, which "should also clearly set out the basis upon which fees are charged", and to ask the client for formal agreement.15
Financial arrangements with clients. A member should exercise care before entering into any kind of financial arrangement with a client, because a financial involvement with a client may impair, or be perceived as impairing, the member's ability to act objectively.16

How the codes relate to R&D and EIS work

Neither code refers specifically to R&D tax deductions or the Enterprise Innovation Scheme. Both apply only to members of the issuing body. A person who prepares R&D or EIS claims for a fee without belonging to either body is not bound by them.13 No official source reviewed for this page reports how many R&D or EIS claim preparers are members of ISCA or SCTP.

Sources

Institute of Singapore Chartered Accountants, Ethics Pronouncement 100: Code of Professional Conduct and Ethics (effective 1 July 2025), paragraph SG010.1. https://isca.org.sg/docs/default-source/ep-100/eps-100/code-of-ethics-for-isca-ep-100-(effective-1-jul-25).pdf (accessed 11 October 2026). Back
Institute of Singapore Chartered Accountants, Ethics Pronouncement 100: Code of Professional Conduct and Ethics (effective 1 July 2025), paragraphs 330.4 A1 to 330.4 A4. https://isca.org.sg/docs/default-source/ep-100/eps-100/code-of-ethics-for-isca-ep-100-(effective-1-jul-25).pdf (accessed 11 October 2026). Back
Singapore Chartered Tax Professionals, Code of Ethics and Professional Conduct (effective 1 September 2026), paragraphs 2.2 and 2.8. https://www.sctp.org.sg/Ethics-Code.pdf (accessed 11 October 2026). Back
Singapore Chartered Tax Professionals, Code of Ethics and Professional Conduct (effective 1 September 2026), paragraphs 3.6 and 3.10. https://www.sctp.org.sg/Ethics-Code.pdf (accessed 11 October 2026). Back
Institute of Singapore Chartered Accountants, Ethics Pronouncement 100: Code of Professional Conduct and Ethics (effective 1 July 2025), cover page revision history. https://isca.org.sg/docs/default-source/ep-100/eps-100/code-of-ethics-for-isca-ep-100-(effective-1-jul-25).pdf (accessed 11 October 2026). Back
Institute of Singapore Chartered Accountants, Ethics Pronouncement 100: Code of Professional Conduct and Ethics (effective 1 July 2025), Part 3 heading and paragraphs 330.1 and 330.2. https://isca.org.sg/docs/default-source/ep-100/eps-100/code-of-ethics-for-isca-ep-100-(effective-1-jul-25).pdf (accessed 11 October 2026). Back
Institute of Singapore Chartered Accountants, Ethics Pronouncement 100: Code of Professional Conduct and Ethics (effective 1 July 2025), Glossary, "Contingent fee", and paragraph 410.8 A1. https://isca.org.sg/docs/default-source/ep-100/eps-100/code-of-ethics-for-isca-ep-100-(effective-1-jul-25).pdf (accessed 11 October 2026). Back
Institute of Singapore Chartered Accountants, Ethics Pronouncement 100: Code of Professional Conduct and Ethics (effective 1 July 2025), paragraphs R410.9 and R410.10. https://isca.org.sg/docs/default-source/ep-100/eps-100/code-of-ethics-for-isca-ep-100-(effective-1-jul-25).pdf (accessed 11 October 2026). Back
Institute of Singapore Chartered Accountants, Ethics Pronouncement 100: Code of Professional Conduct and Ethics (effective 1 July 2025), paragraphs 905.5 A1, R905.6 and R905.7. https://isca.org.sg/docs/default-source/ep-100/eps-100/code-of-ethics-for-isca-ep-100-(effective-1-jul-25).pdf (accessed 11 October 2026). Back
Institute of Singapore Chartered Accountants, Ethics Pronouncement 100: Code of Professional Conduct and Ethics (effective 1 July 2025), paragraphs 380.5 A1 and 380.5 A3. https://isca.org.sg/docs/default-source/ep-100/eps-100/code-of-ethics-for-isca-ep-100-(effective-1-jul-25).pdf (accessed 11 October 2026). Back
Institute of Singapore Chartered Accountants, Ethics Pronouncement 100: Code of Professional Conduct and Ethics (effective 1 July 2025), paragraph 380.19 A1. https://isca.org.sg/docs/default-source/ep-100/eps-100/code-of-ethics-for-isca-ep-100-(effective-1-jul-25).pdf (accessed 11 October 2026). Back
Singapore Chartered Tax Professionals, About SCTP. https://www.sctp.org.sg/About-SCTP.aspx (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Enhanced IRAS-tax agent Relationship Framework (last updated 28 January 2026), section "Accreditation for tax professionals". https://www.iras.gov.sg/quick-links/tax-agents/iras-tax-agent-relationship (accessed 11 October 2026). Back
Singapore Chartered Tax Professionals, Frequently Asked Questions, question "What is SCTP's Code of Professional Conduct and Ethics?". https://www.sctp.org.sg/FAQs.aspx (accessed 11 October 2026). Back
Singapore Chartered Tax Professionals, Code of Ethics and Professional Conduct (effective 1 September 2026), paragraph 8.18. https://www.sctp.org.sg/Ethics-Code.pdf (accessed 11 October 2026). Back
Singapore Chartered Tax Professionals, Code of Ethics and Professional Conduct (effective 1 September 2026), paragraphs 10.5 and 10.6. https://www.sctp.org.sg/Ethics-Code.pdf (accessed 11 October 2026). Back

Summary

ISCA Code of Professional Conduct and Ethics

Scope

Fees and contingent fees in general

Audit and assurance clients

Tax planning

SCTP Code of Ethics and Professional Conduct

Scope

What it says about fees

How the codes relate to R&D and EIS work

Related pages

Sources