PRACTICE AREAS
Tax Law & Customs
We help clients navigate the increasingly complex international tax and customs landscapes governing cross-border corporate structures, supply chains, and foreign direct investments. Operating across Singapore and Vietnam, our practice focuses on designing tax-efficient corporate models, optimizing intercompany transactions, and ensuring seamless compliance with local customs and trade regulations.
Our Core Expertise
Cross-Border Tax Structuring
Designing tax-efficient inbound and outbound corporate structures, managing permanent establishment risks, and leveraging regional networks of Double Taxation Agreements (DTAs).
Transfer Pricing & Intercompany Agreements
Advising on arm's length principles for cross-border transactions, structuring intercompany service fees, software licensing, and cost-sharing arrangements in compliance with international guidelines.
M&A Tax Advisory
Conducting thorough tax due diligence in mergers, acquisitions, and joint ventures, and optimizing transaction documentation for post-closing tax efficiency.
Customs, Duties & Supply Chain Compliance
Advising on import/export regulations, tariff classifications, valuation rules, and free trade agreement origins to optimize regional supply chain costs.
Navigating Singapore
Heightened Transfer Pricing Scrutiny
The Inland Revenue Authority of Singapore (IRAS) strictly enforces mandatory transfer pricing documentation rules. Transactions between Singapore holding companies and regional subsidiaries must reflect clear commercial substance and robust economic benchmarking to avoid steep non-compliance penalties.
Evolving Global Tax Minimums (Pillar Two)
With the ongoing global implementation of the OECD's BEPS 2.0 framework, large multinational groups utilizing Singapore as a hub must carefully manage how minimum effective tax rates interact with local fiscal incentives.
The Gold Standard for Fiscal Efficiency
Singapore remains one of the world's most attractive fiscal hubs, offering a low headline corporate tax rate (17%), an extensive DTA network including active agreements with Spain and France, and no capital gains or withholding taxes on dividends.
A Strategic Gateway for Regional Trade
As a free port with a massive network of Free Trade Agreements, Singapore allows businesses to structure regional distribution hubs that efficiently manage customs duties, utilizing advanced digital customs clearing systems to minimize supply chain friction.
Navigating Vietnam
Aggressive Local Tax Audits
The General Department of Taxation in Vietnam frequently initiates strict, retroactive tax audits focusing heavily on transfer pricing, intercompany management fees, and the validity of corporate tax incentives. Foreign-invested enterprises must maintain meticulous onshore contemporaneous documentation.
Strict Foreign Exchange and Withholding Restrictions
Repatriating profits or servicing cross-border intercompany debt out of Vietnam triggers mandatory withholding taxes and requires strict compliance with State Bank of Vietnam regulations, which can delay fund transfers if documentation is imperfect.
Complex Customs Valuations
Navigating Vietnam's General Department of Customs requires careful management of tariff classifications and customs valuation adjustments, particularly for high-tech components, equipment imports, and raw materials used in localized manufacturing.
Unparalleled High-Tech Fiscal Incentives
Vietnam actively utilizes tax policy to attract qualitative foreign investment. Projects in high-tech sectors, green energy, advanced electronics, and designated economic zones can qualify for massive corporate income tax holidays, preferential 10% tax rates, and exemptions on import duties.
Leveraging a Modernizing FTA Network
Through its active participation in the EVFTA and CPTPP, Vietnam offers international manufacturers a highly optimized launchpad to export goods globally with significantly reduced or zero tariff barriers.
