As a company director or finance professional, there are a range of filing obligations to note. These include company registration confirmations, filing of accounts, and tax filings. In the article below we will summarise these requirements for private companies in Singapore and Hong Kong.
It is worth noting that 2020 was considered an exceptional year, with a range of extensions offered or allowances made for late filings by many authorities in both the company secretarial and taxation space. However, as we settle in to 2021 we cannot assume that any automatic extensions will be granted going forward. As such, all companies should work toward the official deadlines. If you feel that you will be unable to meet filing deadlines, highlight this to your service provider as soon as possible.
In this article, we will cover:
Filing obligations in Singapore
Annual accounts
Annual accounts should be completed each year. The accounts should be audited unless the company qualifies for an audit exemption (for example, as a small company).
The timeline to complete the accounts is partly driven by the deadlines for annual return filings, as detailed below. You should provide all accounting documents to your accounting service provider within one month of the year-end date (two months for those who hold an audit exemption) in order to allow sufficient time for accounting and audit, if applicable.
Annual Return Filing
All Singapore incorporated companies (except those which are exempt) are required to file financial statements with ACRA annually. The timeline for preparing financial statements (audited or unaudited as applicable), holding an annual general meeting and filing the annual return depends on your year-end date and whether the company is listed or not. We summarize the timeline below:
| Listed Companies | Non-listed companies | |
| Preparation of Financial Statements and Holding an Annual General Meeting | 4 months after year-end | 6 months after year-end |
| Filing of Annual Return | 5 months after year-end | 7 months after year-end |
Tax Filing
For Singapore companies, two annual tax filings are required.
The first is the filing of your Estimated Chargeable Income, or ECI. ECI is an estimate of the taxable income, after deducting allowable expenses. This filing is due three months after your year-end date. The filing of ECI is required for all companies except those who have annual revenue below $5m AND nil ECI for the relevant year or assessment.
The main tax filing of the year is due on 30 November 2021. Please note that this year all companies are required to file electronic tax returns, and as such there is no extended deadline of 15 December as in previous years.
Filing obligations in Hong Kong
Annual audited accounts
All Hong Kong companies must complete annual audited accounts unless they are registered as dormant. There is no small company exemption. A copy should be kept by your registered company secretary. The audited accounts are required to be submitted to the Inland Revenue together with your Profits Tax Return when this is due.
The timeline for completing your audited accounts will be driven by your year-end date and Profits Tax Return due date. You should aim to provide all accounting documents to your accounting service provider within two months of the year end date in order to allow sufficient time for accounting and audit.
Annual Return and Business Registration
Annual Returns must be filed within 42 days of the business incorporation anniversary and Business Registration Certificates must be renewed when the demand note is issued. Your corporate secretarial service provider should notify you in advance of the relevant deadlines.
Profits Tax Return
In Hong Kong, Profits Tax Returns are generally issued to companies annually on the first working day of April each year. The Profits Tax Return and any required supplementary forms (including audited accounts) should be filed within one month of the issue date. You should inform your accounting service provider and corporate secretarial service provider immediately when you receive a Profits Tax Return.
All Profits Tax Returns are technically due by the end of April. However, depending on your year-end date, extensions are available. The due date can normally be extended as follows:
| Financial Year End Date | Extended PTR due date |
| 31 December | 15 August following year |
| 31 March | 15 November |
| Other YE date | 30 April – no extension |
Do note that extensions are only available for a 31 December and 31 March year end. If your year-end date is a different date (for example, 30 June or 30 September) no extension is available and you must file your Profits Tax Return and annual accounts within one month of the issue of the Return.
To allow for sufficient time to process and submit your Profits Tax Return, you should have the audited accounts completed and signed one month before the extended due date. For 2021 filings, this means the timeline should be as below:
| Financial Year End Date | Extended PTR due date | Audited Accounts Completion |
| 31 December 2020 | 15 August 2021 | 15 July 2021 |
| 31 March 2021 | 15 November 2021 | 15 October 2021 |
| Other YE date in 2020 | 30 April 2021 (no extension) | 30 March 2021 |
Summary
In Singapore, it is the filing of the annual return that drives the timeline for completing annual accounts. In Hong Kong, it is the filing of the Profits Tax Return. For both locations, it is important to complete the accounting as soon as possible after year-end to allow sufficient time for review and audit (if required).
Our key advice is to be proactive, aim to be well ahead of the deadlines, and flag any delays early. If you need assistance or advice on any of these matters, please reach out to us and we will be pleased to help.
