This is the Centre of Our Practice.
Singapore Tax Structuring
Research on Singapore matters is supported by Teliti, an AI-enabled Singapore tax research platform we built for our own use, run under a documented verification discipline. Every conclusion is checked against primary-source law and signed off by a qualified professional. The benefit to clients is depth and speed, not a substitution for judgment.
Specialist Review
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 the 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:
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Asset mapping and method selection:
Fixed-asset registers mapped to tax categories (section 19 / 19A), write-off periods, and incentive interaction.
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Under-claimed and misclassified allowances:
Reconciliation across entities and jurisdictions, including carry-forward positions and group relief interactions.
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Documentation and audit readiness:
Board-ready schedules, IRAS-facing technical support, and voluntary disclosure support where required.
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Pre-transaction reviews:
Capital allowance impact assessment ahead of acquisitions, disposals, restructurings 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 proceedings and, where matters proceed to the courts, technical tax support provided alongside instructed Singapore legal counsel, including 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, transfer pricing, substance or multi-jurisdiction exposure is involved.
Asia-Pacific and Cross-Border Structuring
Regional tax is coordinated, transparent and increasingly analytical. Frameworks must function across authorities and analytics engines, not only within modelling assumptions.
Our centre of gravity is Asia-Pacific. Recent cross-border engagements have also touched Africa, South America, the United Kingdom and the United States, typically delivered in coordination with specialist partner firms.