Income Tax (Refundable Investment Credits) Regulations 2025

No. S 577

Income Tax Act 1947

Income Tax
(Refundable Investment Credits)
Regulations 2025

In exercise of the powers conferred by section 93B(51) of the Income Tax Act 1947, the Minister for Finance makes the following Regulations:

Citation and commencement

1.  These Regulations are the Income Tax (Refundable Investment Credits) Regulations 2025 and come into operation on 1 September 2025.

Prescribed qualifying activities

2.  Each of the following is a qualifying activity for the purposes of section 93B of the Act:

(a) any investment by a company to increase its productive capacity in any industry, including the manufacturing of any product relating to any industry;

(b) the provision by a company of digital services, professional services and services relating to supply chain management;

(c) the establishment or operation by a company of its headquarters or a centre of excellence in Singapore;

(d) the undertaking by a company of any of the following:

(i) physical trading of commodities;

(ii) trading in commodities derivative instruments;

(iii) acting as a broker for physical trading of commodities or trading in commodities derivatives;

(iv) establishing supply chain management and other functions that relate to the physical trading of commodities;

(e) any research and development or any other activity to promote innovation by a company;

(f) any activity by a company relating to energy efficiency and decarbonisation, including —

(i) improvement in energy efficiency;

(ii) solar power deployment;

(iii) reduction of emissions from greenhouse gases (other than carbon dioxide); and

(iv) carbon capture, utilisation and storage.

Rates for computation of RICs for qualifying expenditure

3.  The rate for computing the RICs for each of the following types of qualifying expenditure incurred by a company in carrying out one or more qualifying activities is 10%, 30% or 50% of the amount of the qualifying expenditure:

(a) any capital expenditure incurred on the provision of a plant, property or equipment;

(b) the following manpower costs:

(i) any wages, salaries and bonuses paid to the company’s employees who are located in Singapore;

(ii) any sums contributed to the Central Provident Fund or other pension funds in respect of those employees;

(iii) any cost incurred to provide any other employment benefits for those employees;

(c) any expenditure incurred to provide training for the company’s employees, including —

(i) any course fees paid to an external training provider;

(ii) any salaries or allowances paid to an external training provider, and the reimbursement of any travelling or transportation expenses incurred by an external training provider, to conduct training for the employees; and

(iii) any allowances given to the employees for attending training and any travelling or transportation expenses incurred for the employees to attend training;

(d) any cost incurred (including as part of the cost of any goods or services) for professional services, consultancy services and technical testing services;

(e) any cost relating to intangible asset acquisition, cost‑sharing agreement for research and development or innovation activity, licensing fees and royalty payments;

(f) any cost of materials and consumables which, upon being used, are consumed or transformed in such a manner that they are no longer useable in their original form;

(g) any freight forwarding and logistics cost for the transportation of goods, the management of such transportation and associated supply chain and logistics process flow;

(h) any financing cost, including interest payments and other related charges.

Factors to determine rates for computation of RICs for each type of qualifying expenditure

4.  In determining the rate for computing the amount of RICs for each type of qualifying expenditure mentioned in regulation 3, the approving authority must consider the following factors, as applicable:

(a) the scale and nature of the company’s investment in Singapore;

(b) the impact of the qualifying activity on the development of any of the company’s trades and businesses or of any industry in Singapore;

(c) in relation to any qualifying activity mentioned in regulation 2(f), the impact of the qualifying activity on —

(i) the resource efficiency of any of the company’s trades and businesses or the industry to which any of those trades and businesses belong; or

(ii) the environmental sustainability of any of the company’s trades and businesses.

Election for payment of RICs to be paid in specified manner

5.—(1)  An awardee company may, at the time of making an application under section 93B(15) of the Act for an amount of RICs to be given to it, make a written election for that amount of RICs to be paid to the awardee company in the following manner:

(a) 20% of the amount of RICs on or before a date specified by the approving authority that falls within the period of 2 years starting from the date of the application;

(b) 30% of the amount of RICs on or before a date specified by the approving authority that falls within the period of 3 years starting from the date of the application;

(c) 50% of the amount of RICs on or before a date specified by the approving authority that falls within the period of 4 years starting from the date of the application.

(2)  An election under this regulation is irrevocable and applies to all RICs applied for under the application.

(3)  If, due to the debiting of an amount of RICs under section 93B(40)(a) of the Act, the amount of RICs for which an election was made under this regulation is reduced (but not to zero), then the reduction is to be made on the basis that an amount of RICs to be paid to the awardee company on a later date is reduced before an amount of RICs to be paid to the awardee company on an earlier date.

Prescribed day for section 93B(29) and (30)( a ) of Act

6.  For the purposes of section 93B(29) and (30)(a) of the Act, the prescribed day is the first day of the period of 3 months before the payout date.

Prescribed day for section 93B(30)( b ) of Act

7.  For the purpose of section 93B(30)(b) of the Act, the prescribed day is the first day of the period of 3 months before the payment date.

Reversal of tax treatment

8.—(1)  This regulation applies if an amount equivalent to any RICs that were given to a company is recoverable from the company (called in this regulation the recoverable RICs) as a result of section 93B(38) and (39) of the Act.

(2)  The qualifying expenditure incurred by the company for which the recoverable RICs were given to the company is not treated as expenditure subsidised by a grant from the Government.

(3)  Subject to the provisions in Parts 5, 6 and 9 of the Act —

(a) the qualifying expenditure mentioned in paragraph (2) is allowable as a deduction under Part 5 of the Act for the purpose of ascertaining the company’s income for the basis period of any year of assessment during which the qualifying expenditure is incurred;

(b) allowances may be made to the company in respect of that qualifying expenditure under section 16, 17, 18C, 19A, 19B, 19D or 20 of the Act (whichever is applicable) for the year of assessment relating to the basis period in which the qualifying expenditure was incurred, or any other year of assessment as may be provided under that provision; and

(c) the provisions in Part 9 of the Act apply in relation to that qualifying expenditure for the purpose of determining the assessable income of the company for the year of assessment relating to the basis period in which the qualifying expenditure was incurred, or any other year of assessment as may be provided under those provisions.

(4)  Where the application of paragraphs (2) and (3) would affect the tax computation of the company for one or more years of assessment, the company must, within 2 months after the service of the written notice under section 93B(36) of the Act or such extended time as the Comptroller may allow, submit a revised tax computation together with supporting documents for each year of assessment that was affected by those paragraphs.

(5)  Where any amount of RICs given to the company were previously brought to tax in one or more years of assessment and those RICs ought not to have been given because of an amendment or revocation of the company’s letter of award under section 93B(35) of the Act, the company must, within 2 months after the service of the written notice under section 93B(36) of the Act or such extended time as the Comptroller may allow, submit a revised tax computation together with supporting documents for each year of assessment in which the RICs were previously brought to tax.

(6)  The Comptroller must, in accordance with the provisions of the Act, give, by way of a revision of assessment made on the company for each year of assessment for which a revised tax computation was submitted under paragraph (4) or (5), relief in respect of the amount of tax paid or payable by the company.

Made on 26 August 2025.

LAI CHUNG HAN

Permanent Secretary,
Ministry of Finance,
Singapore.

[AG/LEGIS/SL/134/2025/12]