Service 01 · Core Practice
Singapore & Cross-Border Tax Advisory
This is the centre of our practice.
We advise multinational groups, SMEs, founders, family offices and private capital on Singapore and Asia-Pacific tax structuring, IRAS engagement and disputes, and the broader cross-border architecture that supports operating and holding decisions.
The work is engaged where structural decisions carry long horizons — restructurings, exits, audit cycles, treaty positions, substance assumptions — and where senior, independent judgment is required to balance technical correctness against commercial and reputational consequence.
Cross-Border Framework
Singapore Holding Company · Incentive & Exemption Frameworks · Residency & Substance
Operating Subs (SG, HK, MY, ID, JP, AU) · Transfer Pricing & Value Realisation
Controversy Readiness · Capital Allowance Schedules · Post-Filing Durability
Singapore Tax Structuring
Singapore is a documentation-driven jurisdiction. Positions that are technically sound but evidentially thin can become difficult to defend years later, often during transactions or audit cycles when remediation is most costly.
- Corporate income tax structuring and rationalisation.
- Reorganisations, mergers and group simplification.
- Incentive and exemption frameworks — including IRAS-administered regimes.
- Residency, place-of-management and central-management considerations.
- Capital allowance governance and optimisation.
- IRAS engagement strategy and pre-emptive position-paper preparation.
- Independent review of legacy positions before they are tested.
Capital Allowance Studies
Capital allowances are often material, but rarely reviewed with the same discipline as structuring. Studies frequently identify unclaimed or misclassified allowances, improving cash tax profile without structural risk.
Studies are typically undertaken before major restructurings, exits or audit cycles, or where historical positions have not been independently reviewed.
Targeted studies focus on:
- Asset mapping and method selection: Fixed-asset registers mapped to tax categories (section 19 / 19A), write-off periods, and incentive interaction.
- Under-claimed and misclassified allowances: Reconciliation across entities and jurisdictions, including carry-forward positions and group relief interactions.
- Documentation and audit readiness: Board-ready schedules, IRAS-facing technical support, and voluntary disclosure support where required.
- Pre-transaction reviews: Capital allowance impact assessment ahead of acquisitions, disposals, or changes in asset use.
Tax Disputes & Controversy
Effective dispute management requires the same structural and evidentiary discipline as the advisory that precedes it.
Disputes are not purely technical exercises. They require judgment on when to concede, where to hold, and how to preserve the client’s commercial and reputational position throughout.
- IRAS audit management: Engagement strategy, information request coordination, position papers and direct liaison with IRAS officers.
- Additional assessments and objections: Review and challenge of additional assessments, preparation of notices of objection, negotiation of revised positions.
- Appeals and resolution: Board of Review and High Court / Court of Appeal support, including technical arguments and expert evidence coordination.
- Voluntary disclosure and remediation: Disclosure strategy, exposure quantification and IRAS engagement to manage penalty and interest outcomes.
- Cross-border dispute coordination: Across authorities and partner firms where treaty interpretation, TP, or multi-jurisdiction exposure is involved.
Arrange a Confidential Discussion
All enquiries are handled directly by Michael Velten under strict confidentiality protocols.