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Capping The
GST Risks With
Robust Internal Controls Framework
On 5 April 2011, the Inland Revenue Authority of Singapore (IRAS) announced a new GST
initiative known as Assisted Compliance Assurance Programme (ACAP). It sets out what is
expected of a company’s framework for good GST risk management and governance. What are
the salient points and how will this initiative affect companies? ICPAS Research Bulletin tells
you more.
The Goods and Services Tax (GST) was introduced Tax Advisor of SIATP). This co-funding is the first of on 1 April 1994 to shift Singapore’s reliance from its kind and highlights the importance that IRAS place direct to indirect taxes. According to IRAS’ in GST compliance. To further sweeten the deal, FY2009/2010 annual report, they recovered S$256 there will be an exceptional one-time full waiver of million from their GST audits and investigations, an penalties for non-fraud errors arising from and almost 29% increase compared to the previous year. voluntarily disclosed in the first ACAP review. Taken In the same assessment period, there were 8,021 together, IRAS said companies can potentially save non-compliance cases. The swelling collection of tax and penalties from GST audits, signals the increasing A Comprehensive Suite of Benefits
need for IRAS to work together with stakeholders to achieve a high level of voluntary tax compliance while The ACAP is chock-full of carrots for eligible keeping compliance cost low. This reinforces the need for businesses to develop a holistic and proactive framework for GST risk management. certifications, the ACAP is also accorded to companies as a badge of honour. Depending on the ACAP comes to the rescue
robustness of the processes and controls of the IRAS announced on 5 April 2011 a voluntary review ACAP applicant, the IRAS would accord the applicant programme to help GST-registered businesses better either an ACAP Premium (5 years) or ACAP Merit manage their GST risk. This is known as the Assisted status (3 years). This denotes the duration that the Compliance Assurance Programme (ACAP), a ACAP status holders may enjoy the benefits. successor to the 2007 Compliance Audit Programme (CAP). It is believed that stronger internal GST Box 1: Benefits of ACAP status
controls and robust risk management framework will lead to lower risks of incorrect GST returns. Thus, lowering the compliance costs for businesses. Simply Step-down of IRAS compliance activities: 3 put, ACAP is the aspirin treatment to help businesses years for ACAP Merit status, and 5 years for manage their ‘migraine’ arising from GST filing. ACAP Premium status unless significant anomalies are noted in your GST declarations What is unique about ACAP, as compared to similar risk-based approaches to tax risk management and Expeditious GST refunds and dedicated officer governance in Australia and the United Kingdom, is to handle GST rulings and resolve your GST the offer from IRAS to co-fund 50%, capped at S$50,000, of the ACAP applicant’s costs of engaging an independent ACAP reviewer (e.g. a CPA firm where the team is lead by an accredited Tax Advisor As participating in ACAP demonstrates a company’s of the Singapore Institute of Accredited Tax commitment to GST compliance, the company must Professionals (SIATP) or an independent in-house meet certain criteria before being eligible. Internal Audit team with one of the team member being an Accredited Tax Practitioner or Accredited Tax The potential benefits to your company include Box 2: Eligibility for ACAP
reduction in time spent on following up with IRAS- ACAP applicants must meet certain criteria to GST compliance activities and savings from potential tax penalty due to the exceptional one-time waiver of Be GST-registered for at least three years Should not be in the process of undergoing a Some pertinent questions that your company should Good tax compliance records with IRAS and consider before adopting ACAP framework include: Is the management committed to allocating Exhibit a proactive management of GST risks by sufficient resources to the GST accounting Established all key controls for the three levels (i.e. Entity, Transaction and GST Reporting) Have its latest financial statements audited and Do we have in place a structural system to Committed to appointing a qualified ACAP Are our accounting systems adequately automated and robust to ensure the completeness and accuracy of our GST So what does ACAP mean for you?
The GST is the second largest contributor to tax revenue, accounting for 23% of the taxes collected by place to ensure that our controls are up-to-date and effective? IRAS for the last financial year (S$6.9 billion). IRAS’ latest compliance initiative is timely, especially when Are there regular checks, reviews and update to ensure that the GST system is well- GST revenues are rising in importance to the nation. However, companies often view GST as an off-shoot established and working effectively? And how much are we willing to pay for this of the accounts receivable and accounts payable system. Most companies manage their GST risks on an ad-hoc basis, which may prove costly and often IRAS has earmarked S$5 million for this programme too late. Hence, ACAP hopes to change that notion over the next five years. It is their hope that at least by pushing GST issues onto the agenda of the board. 100 companies will take up the challenge. Currently, This is a paradigm shift to manage GST risks through SingTel and Cold Storage are among the first few strong internal control processes, thus providing a companies to sign up. The benefits of ACAP and most robust framework towards GST compliance. IRAS’ co-funding are subject to review in three to five The five aspects of an internal controls framework years, implying that the current slew of benefits may change. ACAP can assist businesses in building a environment, risk assessment, control activities, sustainable infrastructure to avoid GST errors and information and communication and monitoring. The reduce GST compliance costs in the long run. tone from the top can make a difference to the way Therefore, if your company meets the ACAP’s an organisation perceives GST risk management. eligibility conditions, do not dally in considering participation. INSTITUTE OF
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