In Singapore’s tax regime, the Inland Revenue Authority of Singapore (IRAS) values punctuality as a cornerstone of corporate compliance. With over 90% of companies now filing on time, being part of the “errant minority” in 2026 carries significant financial and legal risks.
Whether you missed the Estimated Chargeable Income (ECI) deadline or the final Form C-S/C filing on 30 November, the consequences are immediate and escalate quickly. At Hallmark Corporate Services, we help businesses navigate these recovery actions to minimize damage to their reputation and bottom line.
1. The Immediate Consequence: Composition Fines
If your company fails to file by the due date, IRAS typically issues a Notice of Composition. This is essentially an offer to settle the offense without going to court.
- The Cost: Composition sums generally range from S$200 to S$1,000 per offense, depending on your company’s past filing record.
- The Condition: Paying the fine is not enough. You must also file the overdue tax return and supporting documents by the new deadline specified in the notice.
2. The “Estimated Notice of Assessment” (NOA)
When a return is missing, IRAS doesn’t wait indefinitely. They will issue an Estimated NOA based on your company’s past performance or available data.
- The Trap: This estimate is often intentionally higher than your actual tax liability.
- Pay First, Argue Later: You are legally required to pay the tax amount on the Estimated NOA within one month, even if you disagree with the figure.
- Objection Period: You have two months to object to the assessment, but the objection will only be considered once the actual Form C-S/C and financial statements are submitted.
3. Escalating Penalties and Court Summons
If the composition fine is ignored and the return remains outstanding, IRAS moves from administrative penalties to legal enforcement.
- Notice to Attend Court: The company and its directors may be summoned to court. Failure to attend can result in a Warrant of Arrest being issued against the director.
- Court Fines: Upon conviction, a company can be fined up to S$5,000.
- Section 65B(3) Notice: IRAS may specifically direct a director to provide the tax information. Failure to comply with this notice is a criminal offense, carrying a fine of up to S$10,000 or up to 12 months in prison.
[Table showing the hierarchy of IRAS enforcement for late filing]
| Stage of Delay | Typical Action Taken |
| 1–30 Days Late | Composition offer (S$200 – S$1,000) |
| 31–60 Days Late | Estimated NOA issued; 5% late payment penalty applied |
| Persistent Delay | Court Summons for Directors; Section 65B(3) notice |
| 2+ Years Default | Penalty of double the tax assessed + Court fines |
4. Late Payment Penalties: The 5% + 1% Rule
Filing late often leads to paying late. Once an NOA is issued:
- A 5% penalty is added if the tax isn’t paid within 30 days.
- If unpaid after another 60 days, an additional 1% penalty is added every month (capped at 12%).
5. Can You Appeal for a Waiver?
In 2026, IRAS may consider a waiver of the composition sum only if:
- The company has a clean filing record for the last two years.
- The overdue return has been filed and the tax has been paid in full.
- There are exceptional circumstances (e.g., sudden illness of a key officer).
Conclusion: Don’t Ignore the “Reminder” Letter
The “silent treatment” is the costliest strategy when dealing with IRAS. In 2026, automated data sharing between ACRA and IRAS means that missing a filing is flagged almost instantly.At Hallmark Corporate Services, we provide emergency tax filing support and act as your liaison with IRAS to negotiate penalty waivers and resolve estimated assessments. We ensure your business moves back into the “Green Tick” compliance zone swiftly and affordably.