Objection, review and appeal
A taxpayer who disagrees with an assessment lodges a notice of objection within two months stating the grounds. IRAS reviews the objection, may request further information and either amends the assessment or issues a notice of refusal to amend. Within thirty days of the refusal the taxpayer may appeal to the Income Tax Board of Review, an independent tribunal of three members drawn from a panel, which hears the appeal afresh and may confirm, reduce, increase or annul the assessment.1 From the Board an appeal lies on a question of law or mixed law and fact to the General Division of the High Court and from there, with permission, to the Court of Appeal. Tax must be paid notwithstanding objection unless the Comptroller agrees to hold it over.2
Digital-asset disputes before the Board have so far been rare, because the trader-or-investor question tends to settle at the objection stage and because the sums have been modest. The questions most likely to reach the Board are the characterisation of a founder's tranche sales (Chapter II of this Part), the valuation of illiquid tokens received as remuneration (Chapter VI) and the status of staking rewards in an investor's hands (Chapter I). The Board applies the badges of trade with the English and Singapore authorities and has in property and share cases shown a willingness to find trading where the taxpayer's own documents show a profit motive and a short horizon. A crypto taxpayer who wishes to argue investor status before the Board should assemble the evidence described in Chapter I before the dispute begins, because the Board decides on documents and the taxpayer's credibility.
Notes
- Income Tax Act 1947, s. 76 (objections), s. 79 (appeal to the Board of Review), ss. 80–81 (hearing and decision of the Board). ↩
- Income Tax Act 1947, s. 85 (tax to be paid notwithstanding objection or appeal) and ss. 81–82 (appeals from the Board of Review to the General Division of the High Court). ↩
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.