As the tax landscape in Singapore evolves, the Inland Revenue Authority of Singapore (IRAS) has sharpened its risk-based compliance strategy. For finance teams and business leaders, keeping up with standard tax filings is no longer enough—IRAS is digging deeper into line-item details that historically flew under the radar.
Here is a breakdown of the top three focal points IRAS is scrutinizing during tax reviews and audits, along with actionable steps to ensure your company remains compliant.
1. Transfer Pricing (TP): Stricter Enforcement & Exemption Thresholds
Transfer pricing remains IRAS’s highest-priority focus area. IRAS actively cross-checks cross-border and domestic related-party transactions to ensure compliance with the Arm’s Length Principle.
Mandatory Preparation Requirements
Under Section 34F of the Income Tax Act, businesses must prepare contemporaneous Transfer Pricing Documentation (TPD) prior to the tax filing due date if they meet either condition:
- Gross Revenue: Exceeds S$10 million for the financial year.
- Previous Obligation: The business was required to prepare TPD for the immediate preceding period.
Note: Completed TPD must be retained for at least 5 years and submitted within 30 days upon request by IRAS.
Exemption Thresholds
Taxpayers are exempt from preparing detailed TPD for specific related-party transactions if the transaction values fall below the prescribed limits:
| Category of Transaction | Annual Exemption Threshold |
|---|---|
| Purchase / Sale of Goods | S$15,000,000 per category |
| Service Fees / Royalties / License Fees | S$2,000,000 per category |
| Guarantees | S$2,000,000 |
| Related-Party Loans | S$15,000,000 |
| Other Transactions (excluding sales/purchases/loans) | S$2,000,000 |
Audit Insight: Even if your transactions fall below the exemption thresholds, IRAS still expects businesses to maintain underlying commercial justification demonstrating arm’s length pricing. Furthermore, IRAS imposes a strict 5% non-deductible surcharge on any TP adjustments made during an audit, regardless of whether additional tax is payable.
2. Unpaid Accruals: The “Accrue and Didn’t Pay” Dilemma
A common area where businesses trigger tax audits is claiming tax deductions on accrued expenses that remain unpaid for extended periods.
The Core Issue
Under Singapore income tax rules, an expense is deductible when it is incurred—meaning an absolute legal liability to pay has arisen. However, IRAS is scrutinizing long-outstanding accruals (e.g., accrued director fees, management fees, or related-party bonuses) that linger on the balance sheet across multiple Years of Assessment (YAs) without actual cash settlement.
What IRAS Looks For:
- Director’s Fees & Bonuses: Claiming a tax deduction in the year of accrual, but delaying payment for years (or voting/approving the fees after the financial year-end).
- Contingent or Provision-based Accruals: Accruals that are estimates or conditional rather than definitive legal obligations.
- Intercompany Service Charges: Expenses accrued to boost deductions locally, while the paying entity continuously defers settlement.
Key Audit Actions:
- Clawback of Deductions: If IRAS determines an accrual was contingent or had no genuine intention of settlement, the tax deduction will be disallowed and prior YAs reassessed.
- Reviewing Payment Timelines: Finance teams should regularly perform an Accrual Aging Analysis. If an accrued expense is reversed or written off in a subsequent year, it must be added back to taxable income.
3. Capital & Intercompany Accounts: Non-Income-Generating Assets
IRAS is paying close attention to balances sitting in capital and intercompany accounts—specifically non-income-generating assets such as interest-free or low-interest loans extended to company directors, shareholders, or related companies.
Where companies provide interest-free or below-market financing, IRAS scrutinizes both the accounting vs. tax treatment to ensure tax compliance across two major fronts: Employment Benefits (BIK) and Corporate Interest Expense Disallowance (Interest Adjustment).
A. Loans to Directors: Benefits-in-Kind (BIK) vs. Shareholder Capacity
Under Section 2 of the Singapore Income Tax Act, company directors are defined as employees. When a company extends an interest-free or subsidized loan to a director, the interest savings are treated as an employment perquisite (Benefit-in-Kind) taxable under Section 10(1)(b).
- Taxable Benefit Calculation: The taxable interest benefit is computed monthly based on the outstanding loan balance at month-end using IRAS’s prescribed rate: from 1 April 2023, 1.5 percentage points above the 3-month compounded Singapore Overnight Rate Average (SORA) published by the Monetary Authority of Singapore on 1 March and 1 September each year. The company must report this value in the director’s annual Form IR8A.
- The “Shareholder Capacity” Exception: If the loan is granted to an individual strictly in their capacity as a shareholder (and not as a director), the interest benefit is not taxable as employment income. However, IRAS strictly scrutinizes this distinction. To qualify, companies must prove:
- It is a genuine loan with documented repayment terms.
- Loans were offered to all shareholders in proportion to their shareholding.
- Contemporaneous shareholder/board resolutions explicitly approve the advance to them in their shareholder capacity.
B. Interest Adjustments for Non-Income-Generating Assets
Even if an interest-free loan to a director or related company is not taxed as a BIK (e.g., intercompany loans), IRAS targets the lending company’s tax deductions.
- The Core Rule: Under Section 14(1)(a), interest expense is only tax-deductible if incurred on borrowings used to produce taxable income.
- Corporate Tax Adjustment: If a company pays interest on bank loans/borrowings while simultaneously funding non-income-producing assets (such as interest-free intercompany receivables or director advances), IRAS requires an Interest Adjustment:
- Direct Identification Method: If bank borrowings can be directly traced to funding the interest-free loan, the corresponding interest expense is 100% disallowed.
- Total Asset Method (TAM): If funds are commingled, IRAS applies a mathematical formula to attribute a proportionate amount of bank interest expense to the non-income-producing assets, disallowing that portion in the tax computation.
| Scenario | Tax Impact | Focus Area for IRAS Audit |
|---|---|---|
| Interest-Free Loan to Director | BIK Taxable on Director | Must be declared in IR8A based on SORA + 1.5% benchmark rates. |
| Interest-Free Loan to Shareholder | No BIK | Requires proof of genuine shareholder capacity and proportion. |
| Interest-Free Intercompany Loan | Interest Adjustment on Company | Disallows company’s bank interest expense (Direct or Total Asset Method). |
Manager’s Checklist: How to Stay Audit-Ready
To protect your business from tax adjustments, surcharges, and penalties:
- Review Transfer Pricing Annually: Check gross revenue and transaction values against threshold requirements before finalizing your Form C/C-S.
- Clear Out Aged Accruals: Review balance sheet accruals prior to tax filing. Ensure accrued director fees are formally approved within the relevant accounting period.
- Assess Non-Income-Generating Loans: Identify all interest-free advances to directors or related entities, report BIK in IR8A where applicable, and apply proper interest adjustments in tax computations.
- Maintain Complete Audit Trails: Keep supporting invoices, contracts, board resolutions, and TPD for a minimum of 5 years.
Information in this article is correct as at October 2026.
