jaz-cli 2.8.0 → 2.9.0

package/assets/skills/jobs/references/sg-tax/losses-and-carry-forwards.md

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+# Loss Relief and Carry-Forwards for SG Corporate Tax
+
+When a company's deductions and allowances exceed its income, the excess creates carry-forward amounts that can reduce tax in future years. IRAS prescribes a strict set-off order — items must be applied in sequence, and chargeable income cannot go below zero at any step.
+
+---
+
+## Set-Off Order (IRAS Prescribed)
+
+The computation engine applies reliefs in this exact sequence. At each step, the claim is capped at the remaining chargeable income (which cannot go below zero).
+
+| Order | Relief | Source | Carry-forward if excess? |
+|-------|--------|--------|--------------------------|
+| 1 | **Current year capital allowances (CA)** | `capitalAllowances.currentYearClaim` | Yes — becomes unabsorbed CA |
+| 2 | **Enhanced deductions** | R&D, IP, S14Q (uplift portions) | Limited — varies by scheme |
+| 3 | **Unabsorbed CA from prior years** | `capitalAllowances.balanceBroughtForward` | Yes — rolls forward again |
+| 4 | **Unabsorbed trade losses from prior years** | `losses.broughtForward` | Yes — rolls forward (indefinite) |
+| 5 | **Current year donations (250%)** | `enhancedDeductions.donations250Base` x 2.5 | Yes — up to 5 years |
+| 6 | **Unabsorbed donations from prior years** | `donationsCarryForward.broughtForward` | Yes — remaining 5-year window |
+
+**After all reliefs:** the result is **chargeable income**. If it is zero, no tax is payable but the company still files Form C-S.
+
+### How the engine implements the set-off
+
+```
+Adjusted profit = Accounting profit + Add-backs - Deductions
+
+Remaining = Adjusted profit
+  → Less: Current year CA         (capped at Remaining, excess → carry forward)
+  → Less: Enhanced deductions     (capped at Remaining)
+  → Less: Unabsorbed CA b/f       (capped at Remaining, excess → carry forward)
+  = Chargeable income before losses
+
+  → Less: Unabsorbed trade losses (capped at CI before losses, excess → carry forward)
+  → Less: Current year donations  (capped at remaining CI)
+  → Less: Unabsorbed donations    (capped at remaining CI, FIFO, excess → carry forward)
+  = Chargeable income
+```
+
+---
+
+## Trade Losses
+
+### Current year loss
+
+If adjusted profit is **negative** (i.e., the company made a tax-adjusted loss), this is a **current year trade loss**. No further reliefs can be applied — CA, enhanced deductions, and donation claims are all zero because there is no positive income to offset them against.
+
+The current year loss is added to the carry-forward pool:
+
+```
+Unabsorbed losses c/f = Prior year unabsorbed losses + Current year loss
+```
+
+**Input:** A current year loss is detected automatically by the computation engine when adjusted profit < 0. No separate input field is needed — it is calculated from `accountingProfit` + add-backs - deductions.
+
+### Carry-forward of trade losses
+
+| Rule | Detail |
+|------|--------|
+| **Duration** | Indefinite — no time limit |
+| **Condition** | Shareholding test (see below) |
+| **Set-off order** | Applied AFTER CA and enhanced deductions, BEFORE donations |
+| **Cap** | Limited to chargeable income before losses (cannot create or increase a loss) |
+
+**Input:** `losses.broughtForward` — the total unabsorbed trade losses from all prior YAs.
+
+### Carry-back of trade losses (optional)
+
+Companies can elect to carry back current year losses to the **immediately preceding YA**, subject to:
+
+| Rule | Detail |
+|------|--------|
+| **Maximum** | $100,000 per YA |
+| **Condition** | Same shareholding test |
+| **Timing** | Must be elected in the tax return for the loss year |
+| **Effect** | Triggers a refund or reduction of the prior year's tax |
+
+**Note:** Loss carry-back is NOT modeled in the `SgFormCsInput` type. It requires amending the prior year's return and is handled as a separate filing action. The wizard should mention this option but not include it in the computation.
+
+---
+
+## Capital Allowances
+
+### Current year CA excess
+
+If current year CA exceeds the adjusted profit, only the portion up to adjusted profit is claimed. The excess becomes **unabsorbed CA** carried forward.
+
+```
+Current year CA claimed = min(CA available, adjusted profit)
+Excess CA = CA available - CA claimed → carry forward
+```
+
+### Unabsorbed CA from prior years
+
+Applied after enhanced deductions, capped at remaining chargeable income.
+
+| Rule | Detail |
+|------|--------|
+| **Duration** | Indefinite — no time limit |
+| **Condition** | Shareholding test |
+| **Set-off order** | Applied AFTER enhanced deductions, BEFORE trade losses |
+
+**Input:** `capitalAllowances.balanceBroughtForward` — total unabsorbed CA from all prior YAs.
+
+### Combined CA carry-forward
+
+The total CA carried forward to the next YA is:
+
+```
+Unabsorbed CA c/f = Current year CA excess + Prior year CA excess (unused portion)
+```
+
+---
+
+## Donations
+
+### Current year donations
+
+Donations to approved IPCs are claimed at 250% (see `references/sg-tax/enhanced-deductions.md`). The full 250% amount is set off after trade losses.
+
+If the 250% deduction exceeds remaining chargeable income, the excess carries forward.
+
+### Carry-forward of donations
+
+| Rule | Detail |
+|------|--------|
+| **Duration** | **5 years only** (not indefinite) |
+| **Basis** | FIFO — oldest donations used first |
+| **Condition** | Shareholding test |
+| **Set-off order** | Applied AFTER trade losses |
+
+**Input:** `donationsCarryForward.broughtForward` — total unabsorbed donations from prior YAs (max 5 years old).
+
+**FIFO example:**
+
+| Year donated | Original 250% amount | Used in prior YAs | Remaining | Expires after |
+|-------------|---------------------|--------------------|-----------|--------------|
+| YA 2022 | $25,000 | $20,000 | $5,000 | YA 2027 |
+| YA 2023 | $12,500 | $0 | $12,500 | YA 2028 |
+| **Total b/f** | | | **$17,500** | |
+
+When claiming, the $5,000 from YA 2022 is used first (oldest first). If only $10,000 of CI is available, $5,000 comes from YA 2022 (exhausted) and $5,000 from YA 2023 ($7,500 remaining).
+
+---
+
+## The Shareholding Test
+
+Carry-forward claims for trade losses, CA, and donations all require the **shareholding test** to be satisfied.
+
+| Requirement | Detail |
+|------------|--------|
+| **Rule** | >= 50% of the company's shareholders (by voting power) must be substantially the same at two dates |
+| **Date 1** | Last day of the YA in which the loss/CA/donation arose |
+| **Date 2** | First day of the YA in which the loss/CA/donation is to be deducted |
+| **"Substantially the same"** | Same persons holding >= 50% of total voting shares |
+
+**Example:** A company has unabsorbed losses from YA 2024. To claim them in YA 2026:
+- Shareholders on 31 Dec 2024 (last day of YA 2024) must be >= 50% the same as
+- Shareholders on 1 Jan 2026 (first day of YA 2026)
+
+If a majority ownership change occurred between those dates, the carry-forward is **forfeited**.
+
+### Exceptions
+
+- **Listed companies** are exempt from the shareholding test (publicly traded companies have frequent shareholder changes)
+- **Shareholders can be traced through** — if the ultimate beneficial owners are the same even though the intermediate holding company changed, IRAS may accept the claim on appeal
+
+---
+
+## Current Year Loss Scenario (Worked Example)
+
+**Scenario:** Company with an accounting loss, prior year carry-forwards.
+
+```
+Accounting profit (loss):        ($50,000)
+Add-backs:
+  Depreciation:                   $30,000
+  Entertainment:                   $2,000
+  Total add-backs:                $32,000
+Deductions:
+  Actual lease payments:           $5,000
+  Total deductions:                $5,000
+
+Adjusted profit/(loss):          ($23,000)   ← negative = current year loss
+```
+
+**What happens:**
+- Current year CA: $0 (cannot apply CA against a loss)
+- Enhanced deductions: $0 (cannot apply against a loss)
+- Prior year CA: $0 (cannot apply against a loss)
+- Trade losses: $0 (cannot apply against a loss)
+- Donations: $0 (cannot apply against a loss)
+- Chargeable income: $0
+- Tax payable: $0
+
+**Carry-forwards to next YA:**
+- Current year trade loss: $23,000
+- Total unabsorbed losses c/f: prior year $40,000 + current year $23,000 = $63,000
+- Unabsorbed CA: prior year $15,000 + current year CA of $20,000 (could not be claimed) = $35,000
+- Unabsorbed donations: prior year $5,000 (unchanged, ages by 1 year)
+
+---
+
+## Profitable Year with Carry-Forwards (Worked Example)
+
+**Scenario:** Company turns profitable, has carry-forwards from prior years.
+
+```
+Adjusted profit:                  $180,000
+
+Step 1 — Current year CA:       ($45,000)    Remaining: $135,000
+Step 2 — Enhanced deductions:     ($8,000)    Remaining: $127,000
+Step 3 — Unabsorbed CA b/f:     ($35,000)    Remaining:  $92,000
+         Chargeable income before losses:      $92,000
+Step 4 — Trade losses b/f:      ($63,000)    Remaining:  $29,000
+Step 5 — Current year donations: ($12,500)    Remaining:  $16,500
+Step 6 — Prior year donations:    ($5,000)    Remaining:  $11,500
+
+Chargeable income:                 $11,500
+```
+
+**Carry-forwards to next YA:**
+- Unabsorbed losses: $0 (fully absorbed)
+- Unabsorbed CA: $0 (fully absorbed)
+- Unabsorbed donations: $0 (fully absorbed)
+
+---
+
+## Questions for the Wizard
+
+Ask these during Phase 3 (Step 19) of the wizard workflow:
+
+1. **"Does the company have unabsorbed trade losses from prior years? If so, how much?"**
+   - Record in `losses.broughtForward`
+   - Note: the total across all prior years, not per-year breakdown
+
+2. **"Does the company have unabsorbed capital allowances from prior years? If so, how much?"**
+   - Record in `capitalAllowances.balanceBroughtForward`
+
+3. **"Does the company have unabsorbed donation deductions from prior years?"**
+   - If yes: "How much, and from which YAs? (Donations older than 5 years have expired.)"
+   - Record the valid total in `donationsCarryForward.broughtForward`
+
+4. **"Has the company's shareholding remained at least 50% the same since the year the losses/CA/donations arose?"**
+   - If no: the carry-forward claims may be forfeited. Advise the user to check with their tax advisor.
+   - If unsure: flag as a risk item in the workpaper.
+
+---
+
+## Summary: Carry-Forward Input Fields
+
+| Item | Input field | Duration | Condition |
+|------|------------|----------|-----------|
+| Trade losses | `losses.broughtForward` | Indefinite | Shareholding test |
+| Capital allowances | `capitalAllowances.balanceBroughtForward` | Indefinite | Shareholding test |
+| Donations | `donationsCarryForward.broughtForward` | 5 years (FIFO) | Shareholding test |
+
+---
+
+## Common Mistakes
+
+1. **Applying CA against a loss.** If adjusted profit is negative, no CA, enhanced deductions, or other reliefs can be applied. Everything carries forward. The engine handles this correctly, but users sometimes try to force a CA claim in a loss year.
+
+2. **Forgetting the set-off order.** Current year CA comes FIRST, then enhanced deductions, then prior year CA, then losses, then donations. Applying them out of order can produce different carry-forward amounts.
+
+3. **Claiming expired donations.** Donations older than 5 years cannot be carried forward. If a user provides a brought-forward donation amount, verify it only includes amounts from the last 5 YAs.
+
+4. **Ignoring the shareholding test.** If ownership changed significantly (e.g., company was acquired), all carry-forwards may be forfeited. Always ask.
+
+5. **Double-counting current year losses.** If the company made a loss this year, that loss is automatically added to the carry-forward pool by the computation engine. Do not also include it in `losses.broughtForward` (which is prior year losses only).

package/assets/skills/jobs/references/sg-tax/overview.md

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+# Singapore Corporate Income Tax — Overview
+
+Foundational context for Singapore corporate income tax (CIT). Read this first before working on any CIT computation, Form C-S preparation, or tax adjustment classification.
+
+**CLI:** `jaz tax sg-cs --help`
+
+---
+
+## The Basics
+
+| Item | Detail |
+|------|--------|
+| **Tax rate** | 17% flat rate on chargeable income |
+| **Tax authority** | Inland Revenue Authority of Singapore (IRAS) |
+| **Filing portal** | IRAS myTax Portal (https://mytax.iras.gov.sg) |
+| **Who must file** | Every Singapore-incorporated company, including dormant companies and companies with no income |
+| **Accounting standard** | SFRS(I) or SFRS for Small Entities — tax computation starts from accounting profit |
+
+---
+
+## Year of Assessment (YA) Concept
+
+Singapore taxes on a **preceding-year basis**. The Year of Assessment (YA) is the year in which tax is assessed, and it always refers to the income earned in the **prior** financial year (the "basis period").
+
+| Term | Definition | Example |
+|------|-----------|---------|
+| **Basis period** | The financial year in which income was earned | 1 Jan 2025 to 31 Dec 2025 |
+| **Year of Assessment (YA)** | The calendar year immediately following the basis period | YA 2026 |
+
+**Rule:** YA = calendar year in which the basis period **ends** + 1.
+
+| FY End Date | Basis Period | YA |
+|-------------|-------------|-----|
+| 31 Dec 2025 | 1 Jan 2025 - 31 Dec 2025 | 2026 |
+| 31 Mar 2025 | 1 Apr 2024 - 31 Mar 2025 | 2026 |
+| 30 Jun 2025 | 1 Jul 2024 - 30 Jun 2025 | 2026 |
+
+**Non-standard basis periods:** A company's basis period is usually its financial year. If the FY does not end on 31 December, the YA is the calendar year in which the FY ends plus one. A newly incorporated company with a short first FY still follows this rule — the first YA maps to the calendar year after the first FY end.
+
+---
+
+## Form Types
+
+Singapore offers three corporate income tax return forms. The choice depends on company size and complexity.
+
+### Form C-S (Simplified)
+
+The standard SMB return. Most small companies file this.
+
+**Eligibility (ALL must be met):**
+- Annual revenue $5 million or below
+- Only income taxable at the 17% corporate rate
+- NOT claiming any of: group relief, investment allowance, foreign tax credit, carry-back of capital allowances or losses, tax exemption for income from overseas or qualifying debt securities
+
+**18 fields** covering revenue, adjusted profit, capital allowances, enhanced deductions, losses, and tax computation.
+
+### Form C-S Lite
+
+An even simpler version for micro businesses.
+
+**Eligibility (ALL must be met):**
+- All Form C-S eligibility criteria, AND
+- Annual revenue $200,000 or below
+
+**6 fields only:** revenue, adjusted profit/loss, chargeable income, exempt amount, tax payable, and net tax payable.
+
+### Form C (Full)
+
+For companies that do not qualify for C-S or C-S Lite. Requires detailed financial statements, tax computation, and supporting schedules. Not covered by the `jaz tax sg-cs` command — use a tax agent.
+
+---
+
+## Key Deadlines
+
+| Deadline | When | Penalty for Late Filing |
+|----------|------|------------------------|
+| **ECI (Estimated Chargeable Income)** | Within 3 months of financial year-end | No penalty for late filing, but waiver applies only if revenue <= $5M AND ECI is nil |
+| **Form C-S / C-S Lite** | 30 November of the YA (e.g., YA 2026 due 30 Nov 2026) | $200-$1,000 composition penalty, followed by summons if still outstanding |
+| **Form C** | 30 November of the YA | Same as Form C-S |
+| **e-Filing extension** | 15 December of the YA (automatic for e-filing) | Only applies if filing electronically via myTax Portal |
+| **Tax payment** | Within 1 month of receiving Notice of Assessment (NOA) | 5% late payment penalty |
+
+**ECI waiver:** Companies with annual revenue of $5 million or below AND whose ECI is nil (zero chargeable income) do not need to file ECI. All other companies must file.
+
+---
+
+## Income Types (Section 10(1))
+
+Singapore taxes income under these categories:
+
+| Section | Income Type | Common Sources |
+|---------|-------------|----------------|
+| **10(1)(a)** | Gains or profits from trade, business, profession, or vocation | Revenue, service income, commissions |
+| **10(1)(b)** | Gains or profits from employment | Not applicable to companies |
+| **10(1)(c)** | Dividends, interest, or discounts | Foreign dividends (may be exempt), interest income |
+| **10(1)(d)** | Rent, royalties, premiums, or other profits from property | Rental income, royalty income |
+| **10(1)(e)** | Gains not falling in (a)-(d) of an income nature | Miscellaneous income |
+| **10(1)(f)** | Gains from sale of real property / intellectual property | Not usually relevant for SMBs |
+| **10(1)(g)** | Other gains of an income nature | FX gains, insurance proceeds (if revenue nature) |
+
+**For most SMBs on Form C-S:** All income falls under Section 10(1)(a) — trade/business income. The total from the P&L statement is the starting point.
+
+---
+
+## Tax Exemptions
+
+Two mutually exclusive exemption schemes reduce the effective tax rate for qualifying companies.
+
+### Start-Up Tax Exemption (SUTE)
+
+For newly incorporated companies in their **first three YAs**.
+
+| Band | Chargeable Income | Exemption Rate | Tax Saved |
+|------|-------------------|----------------|-----------|
+| First $100,000 | Up to $100,000 | 75% | Up to $12,750 |
+| Next $100,000 | $100,001 to $200,000 | 50% | Up to $8,500 |
+| **Maximum saving** | | | **$21,250 per YA** |
+
+**Conditions:** The company must be incorporated in Singapore, have no more than 20 shareholders throughout the basis period, and all shareholders must be individuals. There are anti-avoidance rules for companies set up to split income.
+
+### Partial Tax Exemption (PTE)
+
+For all other companies (not on SUTE).
+
+| Band | Chargeable Income | Exemption Rate | Tax Saved |
+|------|-------------------|----------------|-----------|
+| First $10,000 | Up to $10,000 | 75% | Up to $1,275 |
+| Next $190,000 | $10,001 to $200,000 | 50% | Up to $16,150 |
+| **Maximum saving** | | | **$17,425 per YA** |
+
+**Note:** PTE applies automatically unless SUTE is elected. For the `jaz tax sg-cs` input, set `exemptionType` to `'sute'`, `'pte'`, or `'none'`.
+
+---
+
+## CIT Rebate
+
+IRAS occasionally grants a CIT rebate (percentage discount on gross tax, subject to a cap). Rebates vary by YA and are set in the annual Budget.
+
+| YA | Rebate Rate | Cap |
+|----|------------|-----|
+| 2024 | 50% | $40,000 |
+| 2025 | 50% | $40,000 |
+| 2026 | 40% | $40,000 |
+
+The `jaz tax sg-cs` engine applies the correct rebate for the given YA automatically. If a YA has no rebate in the schedule, the rebate is zero.
+
+---
+
+## One-Tier Dividend System
+
+Singapore operates a **one-tier corporate tax system**. Once a company pays tax on its chargeable income, all dividends paid to shareholders from that income are **tax-exempt** in the hands of the shareholders.
+
+**For CIT computation:**
+- Dividend income received from Singapore-resident companies is **fully exempt** under Section 13(26)
+- This income should be added back as a non-taxable item (`addBacks.exemptDividends`) and excluded from chargeable income
+- The dividend itself is not subject to withholding tax
+
+---
+
+## Withholding Tax
+
+Withholding tax applies to certain payments to non-residents (royalties, interest, technical fees, management fees, rent). For most SMBs filing Form C-S:
+
+- WHT is **not a Form C-S field** — it is remitted separately to IRAS
+- If WHT applies, the company cannot file Form C-S (one of the disqualifying criteria is claiming foreign tax credit)
+- If you encounter WHT obligations, recommend Form C and a tax agent
+
+---
+
+## Tax Computation Flow (High Level)
+
+This is the conceptual flow from accounting profit to net tax payable. Each step maps to sections of the `SgFormCsInput` type.
+
+```
+Accounting Profit (from P&L)
+  + Add-backs (non-deductible expenses)
+  - Further deductions (non-taxable income, IFRS 16 reversal)
+  = Adjusted Profit / Loss
+  - Capital Allowances (current year + brought forward)
+  - Enhanced Deductions (R&D, IP, donations 250%)
+  = Chargeable Income before Losses
+  - Loss Relief (unabsorbed losses brought forward)
+  - Donation Relief (unabsorbed donations brought forward)
+  = Chargeable Income
+  - Exemption (SUTE or PTE)
+  = Taxable Income
+  x 17%
+  = Gross Tax
+  - CIT Rebate
+  = Net Tax Payable
+```
+
+---
+
+## Practitioner Tips
+
+**Start with the P&L.** Every CIT computation starts from the accounting net profit or loss. Pull the P&L from Jaz for the basis period. The bottom line is your `accountingProfit` input.
+
+**Revenue determines form type.** If revenue exceeds $5M, the company cannot file Form C-S. If revenue is $200K or below, it qualifies for C-S Lite (fewer fields, simpler process).
+
+**Ask about SUTE eligibility.** New companies in their first 3 YAs can save up to $21,250/YA with SUTE. Always ask: "Is this company within its first three Years of Assessment?" and "Does it have 20 or fewer individual shareholders?"
+
+**Accounting depreciation is ALWAYS added back.** This is the single most common add-back. Depreciation per the books is non-deductible — capital allowances (tax depreciation) replace it. No exceptions.
+
+**Keep it stateless.** The `jaz tax sg-cs` engine is a pure computation tool. It does not store or retrieve prior-year data. The agent must provide carry-forward balances (unabsorbed losses, unabsorbed CA, unabsorbed donations) from the user or prior-year workpapers.
+
+**Common SMB profile:** Revenue under $5M, standard trade income, no foreign tax credits, no group relief. This describes the vast majority of companies that file Form C-S.