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Singapore Group Relief 2026: Section 37C Guide to Transferring Losses Within a Corporate Group

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One of the easiest tax wins available to a Singapore corporate group is also one of the most overlooked: the group relief system under Section 37C of the Income Tax Act 1947. Group relief lets a profitable company in a Singapore group absorb the unutilised losses, capital allowances, and donations of a loss-making sister company in the same year of assessment, immediately reducing the group’s overall tax bill.

Despite being on the statute books since Year of Assessment 2003, group relief is still under-claimed. SMEs often assume it is reserved for listed conglomerates. Foreign-headquartered groups sometimes miss it because their tax accountants overseas have never encountered Singapore’s specific 75% ownership test. And finance teams under close-of-year pressure occasionally miss the form-filing deadline.

This 2026 guide walks through who qualifies, what can be transferred, the documentation required, and the most common mistakes we see Singapore groups make when claiming group relief.

What Group Relief Does

Group relief allows a “transferor” company in a Singapore group to surrender certain unutilised tax items to a “claimant” company in the same group, where they are deducted against the claimant’s assessable income for the same year of assessment.

According to the Inland Revenue Authority of Singapore (IRAS), the system was introduced under Section 37C from Year of Assessment 2003 and is the principal mechanism by which corporate groups in Singapore consolidate tax positions on a current-year basis.

The transferable items are:

Critically, only current-year items qualify. Prior-year unabsorbed items must instead be carried forward by the transferor company itself (subject to the shareholding test) or carried back under the loss carry-back relief — they cannot be group-relieved.

The 75% Group Test

Two companies are in the same group only if all of the following are met:

The shareholding must be maintained throughout the entire continuous period of the relevant year of assessment. A change in shareholding part-way through the year — for example, a 60% sale to an external investor in October that drops the ownership below 75% — disqualifies the company for that year of assessment.

Foreign-incorporated parents are permissible only if a Singapore-incorporated holding company in the chain owns at least 75% of both the transferor and claimant. Foreign companies cannot themselves be transferors or claimants.

Order of Set-Off

Within a single year of assessment, the claimant company must set off its own current-year items first, before applying any group-relieved items. The order is:

  1. Claimant’s own current-year capital allowances against trade income
  2. Claimant’s own current-year trade losses against other income
  3. Claimant’s own current-year donations against statutory income
  4. Group-relieved capital allowances
  5. Group-relieved trade losses
  6. Group-relieved donations

This sequencing matters because it can change the optimum surrender amount. Over-surrendering items that the transferor could have used itself wastes the relief.

How to Make the Election

Group relief is not automatic. Both companies must elect into it, separately, on prescribed forms.

Transferor company: files Form GR-A with the amount of items it agrees to surrender, signed by both companies.

Claimant company: files Form GR-B with the amount it claims, signed by both companies.

The forms must be filed by the time the claimant company files its tax return for the relevant year of assessment, which for most Singapore companies is 30 November following the end of the basis period. Late forms or inconsistent figures between Form GR-A and Form GR-B are commonly rejected.

Before filing, both companies should also have lodged their Estimated Chargeable Income (ECI) on time, as group relief interacts with the ECI position.

Worked Example: A Two-Company Group

HoldCo Pte Ltd is a Singapore-incorporated parent holding 100% of TradeCo Pte Ltd and 100% of LossCo Pte Ltd. Both subsidiaries have a 31 December accounting year-end. For YA 2026:

If LossCo elects to surrender its S$300,000 loss to TradeCo, TradeCo’s chargeable income falls to S$500,000. At the prevailing 17% headline corporate tax rate, group relief saves the group S$51,000 in current-year tax.

Without group relief, LossCo would have to carry forward its S$300,000 loss to future years, where it would only be relieved when LossCo itself returns to profitability — and only if LossCo continues to satisfy the shareholding test on a year-by-year basis.

Group Relief vs Loss Carry-Back vs Carry-Forward

Singapore offers three distinct loss-utilisation mechanisms. Each has different conditions and different best-fit scenarios:

Mechanism What it does Best for
Group relief (s37C) Surrenders current-year items to a sister company in the same year of assessment Groups with a profit-maker and a loss-maker in the same year
Loss carry-back (s37E) Carries current-year losses back up to S$100,000 to the immediately preceding YA Companies that were profitable last year and loss-making this year
Loss carry-forward Carries unabsorbed items forward indefinitely (subject to shareholding test) Standalone companies or losses exceeding the carry-back cap

The three are not mutually exclusive. A loss-making company can carry back the first S$100,000, group-relieve some of the balance to a profitable sister company, and carry forward whatever remains — provided each item is properly tracked.

Common Mistakes Singapore Groups Make

From hundreds of group relief claims, these errors recur:

Interaction With Other Reliefs and Incentives

Group relief interacts with several other Singapore reliefs:

For a deeper look at company-level loss treatment generally, see our companion piece on Capital Allowances in Singapore, and on Foreign-Sourced Income Exemption.

Year-End Planning Checklist

Before the financial year closes, run this five-point check:

  1. Confirm all Singapore-incorporated group entities have the same accounting year-end.
  2. Map the shareholding chain and verify 75% is held throughout the entire year.
  3. Project chargeable income and current-year losses for each entity.
  4. Decide the optimum surrender amount, factoring in available carry-back and carry-forward alternatives.
  5. Diarise Form GR-A / GR-B preparation alongside Form C-S / Form C tax-return work.

How Raffles Corporate Services Can Help

Group relief is one of the cleanest planning tools available to Singapore corporate groups, but it punishes loose paperwork. Our tax team helps clients map their shareholding chain, optimise current-year surrender amounts, prepare Form GR-A and Form GR-B, and coordinate the filings with corporate tax returns and ECI submissions.

If your group has profitable and loss-making Singapore subsidiaries, talk to Raffles Corporate Services before the year of assessment closes. A few days of planning routinely saves five-figure or six-figure tax amounts.

— The Editorial Team, Raffles Corporate Services

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