Singapore has a relatively simple tax system in comparison to most other tax systems in the world. However, regardless of how simple the tax system is, as the tax laws are based on legal principles, the enforcement of those tax laws is often contested and may create tax disputes.
Tax Disputes
Tax disputes arise mostly because there is a disagreement between the taxpayer and the Inland Revenue Authority of Singapore (IRAS) as to the application of the legal principle (for example, one of the most disputed areas is regarding the source or taxability of income), and/or to the facts and circumstances.
In general, the process of a tax dispute is:
File an objection with IRAS
If no agreement is reached during the objection stage, the dispute will be passed to the IRAS Appeals Unit for a determination.
If you wish to appeal against the determination, our team can assist you in appealing to the Income Tax Board of Review.
A taxpayer may further appeal to the High Court, and subsequently to the Court of Appeal, if dissatisfied with the decision of the Income Tax Board of Review on a question of law. Our team can advise and represent clients through each stage of the tax dispute resolution process.
Tax Investigations & Field Audit
Unlike a tax dispute, which is generally initiated by the taxpayer, a tax investigation or tax audit is initiated by IRAS if it has doubts regarding the sources of income, or the completeness and accuracy of the tax returns filed by taxpayers (in respect of both companies and individuals). For example, one of the most focused tax audit areas in recent years is a company's permanent establishment. In general, tax audits and investigations are carried out by IRAS's Audit & Investigation Unit.
In general, the process of a tax investigation is:
The taxpayer receives the tax notification. Between receiving the tax notification and the first meeting or initial interview, the taxpayer should gather all documents and information requested in the notification.
Attend initial interview. In general, the taxpayer should contact IRAS within the timeframe specified in the tax notification to arrange for the initial interview.
IRAS conducts the field audit.
IRAS will review the taxpayer's tax position after the field audit has been conducted.
Attend settlement meeting with IRAS.
Propose a fine. In the case of understatement, IRAS will assess the understated income or profits and impose a penalty on the taxpayer. In the case of tax evasion, IRAS may refer the case to the Attorney-General's Chambers for criminal prosecution, in addition to assessing the understated income or profits and imposing a penalty.
Prevention of Tax Disputes & Investigations
HKWJ Tax Consultants Pte. Ltd. can assist you to identify and mitigate potential tax disputes and investigations by:
Conducting regular tax health checks to identify possible tax risks.
Advising on preparation of necessary documents to substantiate tax positions.
Advising on commercial or tax substance to substantiate claims.
Applying for an advance ruling with IRAS before engaging in any activity or transaction.
Our Services
IRAS has a specialised unit for tax audits and investigations. They conduct in-depth reviews and investigations on selected cases. The selected taxpayers will likely have to spend significant time and resources dealing with the tax audit or investigation, hence it is best to engage a professional tax advisor to:
Provide professional assistance to clients who are selected for a tax audit.
Assist in planning a proper strategy to minimise the tax and/or penalty, if any, for the client.
Attend interviews with IRAS, handle tax enquiries from IRAS, and prepare and file settlement proposals with IRAS.
As your legal and tax representative, HKWJ Tax Consultants Pte. Ltd. can assist you in managing and resolving tax disputes, tax audits, and investigations with IRAS at any stage of the process. Our services include but are not limited to:
For tax dispute
Assist with preparing and filing an objection (including a late objection).
Assess and advise whether there is merit for litigation, or whether litigation is appropriate.
Advise, assist, and represent in appeal and litigation procedures.
For tax investigation
Formulate strategy to handle the tax investigation.
Retrieve all documents and information requested, estimate the time required to retrieve documents and information if not readily available, and arrange for the interview.
Accompany you to the interview, field audit, and settlement meeting.
Prepare settlement proposals or further proposals to IRAS on your behalf.
Can I Change my Tax Advisor / Representative?
Yes — you can change tax advisors at any time, even in the middle of a financial year or close to filing deadlines. In fact, many of our clients come to us because they were unhappy or uneasy with their previous tax advisor.
Common reasons businesses and individuals decide to switch include:
Slow response or last-minute rush You only hear from your advisor right before deadlines, or they take too long to respond to emails and calls. Also, you have not been informed of any tax letters or correspondence issued by IRAS.
Lack of proactive tax planning You feel your advisor is only doing basic compliance (filling in forms, filing returns), but not helping you achieve tax efficiencies or spot opportunities in advance. You also do not know the potential tax risks of certain tax matters and the potential enquiries from IRAS.
Unexpected or opaque fees You receive invoices that are higher than expected, with limited breakdown, or you are charged for every short question.
Errors, amended filings or IRAS questions Your tax filings often need correction, or you are frequently contacted by IRAS to clarify basic matters.
Poor understanding of your business or cross-border situation Your advisor does not really understand your industry, your group structure, or your international footprint (e.g., Singapore-China / Singapore-overseas structures).
Minimal support during IRAS enquiries or tax audits When IRAS asks questions, you feel left alone or receive generic answers that do not properly defend your position.
No clear point of contact Your case is passed from one junior to another, and you need to repeat your situation multiple times.
If any of this sounds familiar, it may be time to consider a change.
Is Switching Tax Advisors Complicated?
In most cases, the process is straightforward. You do not have to wait until year-end or the next filing season to make a move.
When you appoint HKWJ Tax Consultants Pte. Ltd. as your new tax adviser, we:
Review your situation and needs We start with a confidential discussion to understand:
Your business structure or individual tax circumstances
Any existing IRAS enquiries or audits
Your concerns with your current advisor
Potential tax exposures or areas of concern
Upcoming key deadlines
Coordinate with your previous advisor (if you wish) With your consent, we can:
Contact your previous advisor professionally to arrange the handover of files and working papers.
Request copies of past returns, computations, and relevant correspondence.
Clarify any outstanding issues or pending filings.
Contact your previous advisor professionally to arrange the handover of files and working papers.
Check your past filings for risk and opportunities Once we have the necessary information, we typically:
Review recent Singapore tax returns (Corporate Income Tax, Goods and Services Tax, etc.) and assess your tax position
Identify potential risks (e.g., positions that may attract IRAS attention)
Highlight planning opportunities or reliefs that may not have been fully utilised.
We will then work with you to prioritise the areas to address, from straightforward corrections to more strategic tax planning.
Take over IRAS communication and deadlines After appointment, we can:
Serve as your authorised representative with IRAS
Ensure IRAS records are updated as needed
Track and manage key filing and payment deadlines
We aim to keep you fully informed and avoid unexpected issues.
Begin Your Journey with HKWJ Tax Consultants Pte. Ltd.
Your Global Partner for Tax, Corporate & Compliance Solutions
Based in Singapore, HKWJ Tax Consultants Pte. Ltd. makes getting started simple. Tax compliance, accounting, incorporation, business support — our team tailors every solution locally, handled with the discretion and care you expect. Contact us to see how we can support your goals.
