We advise on the structural and operational design of cross-border arrangements, and on the policies, documentation and dispute support that follow.
The Work
Policy and methodology
- Policy design across goods, services, financing, royalties, IP, capital flows and intra-group support.
- Method selection and benchmarking strategy across Asia-Pacific and broader international footprints.
- Coordination of policy with operational reality: alignment between contractual, functional and economic substance.
Documentation
- Master file, local file and country-by-country reporting preparation and review.
- IRAS transfer pricing documentation alignment.
- Documentation refresh for groups whose operating model, footprint or value chain has materially changed.
Disputes and controversy
- Audit defence and information request management.
- Advance Pricing Arrangements: strategy, preparation and negotiation.
- Mutual Agreement Procedures and competent authority coordination.
- Settlement analysis and post-settlement governance.
International structuring
- Cross-border operating model design: principal structures, regional hubs, IP and financing platforms.
- Substance and economic presence alignment.
- Treaty interaction and withholding tax pathway design.
- Pillar Two impact assessment on existing and proposed structures.
When the work is engaged
- Group restructuring, market entry, divestment or post-acquisition integration where transfer pricing architecture is in motion.
- Pillar Two implementation forcing structural reassessment.
- IRAS or regional authority enquiry, audit or APA negotiation.
- Family office or fiduciary platforms where intra-group financing, IP or service flows have grown without coordinated policy.
- Senior independent review of existing positions ahead of transactions or audit cycles.