Tax Services

The world as we know it is always in a constant flux, not least with changes in tax laws, regulations and rules becoming commonplace. Invariably, tax strategies that may work yesterday may not be viable today. Enterprising businesses must consider tax issues and its ensuing implications in parallel with, and not as an afterthought with other commercial matters.

CLA Global TS’s Tax Services Team plays a vital role in steering our clients toward sustainable and workable solutions in today’s ever changing tax landscape and clients appreciate our personal and regular involvement throughout their entire business lifecycles. We are committed to help our clients to resolve their most pressing tax issues and to achieve various business / personal goals, ranging from (re)structuring, acquisitions, investments, divestments and / or succession planning, to name a few, in the most pragmatic and tax efficient manner.

Our Team provides a full suite of tax solutions to assist enterprises and individuals alike to meet their tax compliance obligations and manage / resolve a broad range of tax issues.





Business / Corporate Tax

As businesses expand their operations into new markets, the complexity of managing tax risks and compliance with reporting requirements multiply. Managing businesses’ tax exposure in this dynamic business landscape requires in-depth expert knowledge of all relevant taxes. To maximise economic returns, it is vital for businesses to put in place effective tax plans to make the most out of the applicable tax reliefs and incentives. This is especially important for companies undergoing restructuring or embarking on new business ventures.

Broadly, our corporate tax services cover the following:

Tax Advisory

  • • Identify and pursue opportunities for Singapore tax incentives, reliefs or grants to maximise tax savings
    • Examine Singapore and cross-border withholding tax and permanent establishment issues
    • Advice on local and cross-border structuring to ensure tax efficiency taking into account tax losses, group relief, capital gains rules, etc.
    • Review contractual agreements to enhance tax risk management
    • Tax due diligence for IPOs and M&A transactions
    • Advice on tax implications of fund-raising activities through loans, share and asset sales
    • Deal with transaction tax costs such as stamp duty
    • Explore the applicability of relevant tax treaties in cross-border tax planning

Tax Compliance

  • • Preparation and filing of Singapore corporate/partnership tax returns and computations
    • Assistance with withholding tax compliance matters
    • Attend to queries raised by the Inland Revenue Authority of Singapore (IRAS)
    • Assist with tax audits and investigations initiated by the IRAS
    • Handle objections and requests for advance rulings, voluntary disclosures of errors




International Tax

Businesses are expanding into international markets to generate potential revenue. At the same time, countries around the world have been adapting their tax policies and rules to ensure that global businesses pay their fair share of taxes. As a result, businesses often have to contend with a myriad of complex and unfamiliar tax regulations, therefore increasing their tax risks and costs. As international tax advisors, we add value to our clients by working with them to develop a global tax strategy, leading them through tax regulations as well as providing practical tax advice and solutions. With our knowledge and experience, we are well positioned to take care of your tax needs so that you can focus on what you do best – running your business.

  1. Tax advice and planning for inbound investments in structuring, financing, exploring tax incentives, repatriation of earnings and exit from investments.
  2. Country-specific study for outbound investments on the suitability of jurisdictions with focus on tax aspects
  3. Group structure and business substance review, rationalisation and restructuring for tax efficiency
  4. Cross- border M&A in relation to pre-acquisition tax due diligence, planning and structuring advice and post-acquisition integration

     5. Tax advisory support for cross border transactions including:

  • • Tax efficient structuring of transactions
    • Navigating permanent establishment issues
    • Withholding tax implications
    • Application of tax treaties
    • Review of contractual agreements
 
 
 
 

Goods & Services Tax

In a globalised business landscape with fast changing business model and new international trend for indirect tax, it is vital for companies to be aware of and stay on top of GST developments to minimise tax compliance risks and avoid adverse impact on businesses. Risk of non-compliance may give rise to hefty penalties imposed by the tax authorities.

Our GST services include:

  • • Apply for GST registration/exemption from GST registration or de-registration
    • Review and e-filing of GST returns, and assist with the claiming of pre-registration input tax claims
    • Assist with replies to GST queries raised by the Inland Revenue of Singapore
    • Advice on GST treatment of day-to-day business transactions
    • Perform due diligence reviews
    • Review and improve GST compliance capabilities through: Assisted Self-Help Kit (ASK) review for voluntary disclosure of errors, Assisted Compliance Assurance Programme (ACAP), GST health check
    • Evaluate and assist in the application/renewal for GST relief schemes (e.g. Major Exporter Scheme, Approved Contract Manufacturer & Trader Scheme etc) through ASK review


Transfer Pricing

Transfer pricing has been gaining attention by the tax authorities as well as businesses with the slew of recent updates to the transfer pricing regulations and guidelines, both internationally and in Singapore. To name a few, the Organisation for Economic Co-operation and Development (“OECD”) updated the OECD Transfer Pricing Guidelines in January 2022 and closer to heart, the Singapore Tax Authority, the Inland Revenue Authority of Singapore (“IRAS”) released the 6th update to the Transfer Pricing Guidelines in August 2021. This is no surprise as transfer pricing influences the level of both direct and indirect taxes that governments collect while at the same time, it is often perceived by tax authorities as a tool used by businesses to shift profits overseas. Against the backdrop of the Covid pandemic in which governments have increased their spending exponentially and the rise in cross border transactions, transfer pricing is likely to continue to be a key focus area of the tax authorities.

Through being part of the CLA Global network, we are able to provide a one-stop transfer pricing services from Singapore and foreign tax jurisdiction perspectives.

We provide a full range of transfer pricing solutions which include:

  • Transfer pricing risk review;
  • Transfer pricing planning and policy setting;
  • Transfer pricing documentation;
  • Transfer pricing implementation; and
  • Transfer pricing controversy and defense.
 
 

Transfer Pricing Risk Review

Even if companies do not need to prepare mandatory transfer pricing documentation, companies are still encouraged to conduct regular transfer pricing risk review/assessments of their existing transfer pricing policies amidst the changing international tax/transfer pricing landscape to ensure they meet their transfer pricing obligations. In particular, transfer pricing risk review is even more important when one expects or has new related party transactions or significant events which include the following scenarios in order to identify and mitigate the transfer pricing risks:

  • Entrance into new markets/business lines (more information on international tax service, click here);
  • Restructuring (more information on international tax service, click here);
  • Mergers & acquisitions (more information on M&A Tax Service, click here); and
  • External events which disrupt the operational/supply chain model.

We are able to assist companies in the transfer pricing risk reviews in such scenarios. Our expertise is not just in providing transfer pricing risk review, but we are able to provide a holistic tax solution spanning from transfer pricing to other areas such as international tax as well as mergers & acquisitions tax services according to your business needs.

Transfer Pricing Planning and Policy Setting

Getting transfer prices right from the first instance is very important in terms of mitigating the company’s transfer pricing risks. It is costly and often challenging to defend transfer pricing policies that are not robust. In addition, transfer pricing can be used as a strategic tax planning tool to optimize the company’s global tax position.

We are able to provide companies with transfer pricing advisory support during the stage of transfer pricing planning and policy setting by:

  • Reviewing and assessing the consistency and acceptability of the proposed transfer pricing policies based on OECD’s requirements and from the standpoint of the relevant jurisdiction(s);
  • Developing and aligning transfer pricing strategies with the company’s global business goals and objectives taking into consideration the Singapore and overseas tax requirements;
  • Preparing/reviewing transfer pricing policy documents;
  • Preparing/reviewing intercompany agreements; and
  • Applying for unilateral or bilateral/multilateral advance pricing arrangements (“APAs”) to have certainty of the transfer prices.
 
 

Transfer Pricing Documentation

From the Year of Assessment 2019 onwards, companies must prepare transfer pricing documentation for their related party transactions undertaken in a basis period when:

  • Gross revenue derived from their trade or business is more than S$10 million for that basis period; or
  • Transfer pricing documentation is required to be prepared for the previous basis period.
 

Even if it is not mandatory to prepare transfer pricing documentation, companies are still encouraged to do so especially if their transfer pricing risks are high as transfer pricing documentation serves as a first line of defense for the companies’ transfer prices.

We are able to assist companies in the following:

  • Preparing transfer pricing documentation (Full/Simplified) from a Singapore transfer pricing perspective;
  • Preparing group master file and transfer pricing documentations for the jurisdictions that the Group operates in that are in compliance with both Singapore and foreign tax jurisdictions transfer pricing requirements;
  • Country-by-Country reporting;
  • Reviewing existing transfer pricing documentation to ensure compliance with Singapore requirements; and
  • Preparing benchmarking studies to support arm’s length pricing of related party transactions where required.
 
 

Transfer Pricing Implementation

Setting transfer pricing policies may be challenging but achievable for most companies. However, ensuring that the transfer pricing policies are implemented effectively throughout the various departments/businesses of the companies and to minimize year-end adjustments may be much bigger challenges as they have real costs to the companies.

We are able to assist companies in navigating through these operational transfer pricing challenges by assisting companies in:

  • Developing and documenting a customized operational transfer pricing framework, which includes how the transfer prices are set and monitored, the roles and responsibilities of each party involved, etc taking into consideration the companies’ risk appetite and resources; and
  • Reviewing transfer pricing calculations.
 
 

Transfer Pricing Controversy & Defense

With the increasingly sophisticated tax authorities worldwide trying to maintain/increase their tax revenue, there is a rise in transfer pricing audits as well as transfer pricing controversies.

 

We are able to assist companies in:

  • Defending the transfer pricing policies and transfer pricing outcomes in transfer pricing audits; and
  • Applying for mutual agreement procedures (“MAPs”) to resolve double taxation.




Private Wealth and Fund Management

High net worth individuals, business owners and family groups often face challenges and difficult decisions that affect not only the success of their businesses, but also their personal goals. Whatever the end goal is (for example, public listing, entry into new markets, asset protection, protecting and extending their legacies), it is imperative to respond accordingly to evolving market conditions, new legislations and address the potential tax consequences before they arise.

 

 

Our team of dedicated private wealth tax specialists work closely with clients to navigate the ever-changing tax landscape in varied matters regarding estates, trusts or private foundations and other philanthropic activities and to help with the development and implementation of an estate plan customised to the needs of the client.

  • Advice on tax-efficient (re)structuring of investments via the various types of legal structures and the choice of jurisdiction
  • Advice on the applicability of tax incentives and/or regulatory licenses and assistance with the implementation of the structure and relevant incentives / licenses
  • Advice on tax issues concerning trusts, funds, fund management companies and family offices
  • Assisting in the preparation and filing of tax returns for trustees, business owners and/or family members
  • Common Reporting Standard (“CRS”) and Foreign Account Tax Compliance (“FATCA”) due diligence studies and reporting obligations

 


Global Mobility and Expatriate Tax

In light of a globally mobile workforce, an important consideration for global employers is to ensure that they and their employees are fully aware of and comply with local filing requirements. A well-organised assignment arrangement require employers to strike a balance between competitive compensation and cost control, as well as putting in place effective policies and procedures for regulatory compliance. The same also applies to expatriates as the consequences of erroneous tax filings can result in penalties.

  • Prepare, review and file Singapore individual income tax returns (Form B1), Return of Employee’s Remuneration (Form IR8A) and Cessation Return (Form IR21)
  • Provide arrival/departure counselling on individual tax matters for inbound or outbound employees
  • Develop tax-efficient employment remuneration packages
  • Global/regional coordination of expatriate tax services
  • Develop and implement tax equalisation policy
  • Assist in queries raised by the IRAS, voluntary disclosures of errors, tax audits and investigations
  • Apply for tax incentives/rulings
 




Personal Tax

Professionals who conduct businesses in their own names through sole-proprietorships/partnerships hold the responsibility to reflect their earnings accurately in their personal tax returns. Omissions could result in tax audits launched by the IRAS, which can be time consuming, costly and stressful. It would be wise to review your current situation and plan ahead to avoid omissions and at the same time, maximize your rightful benefits.

Our team of professionals stands ready to assist you with:

  • Prepare, review and file Singapore individual income tax computations and returns to maximize your rightful benefits and claims under the existing tax legislations
  • Perform a tax review of past returns and to recommend and assist in risk mitigating actions
  • Assist in queries raised by the IRAS, voluntary disclosures of errors, tax audits and investigations
  • Apply for tax incentives/rulings




Mergers and Acquisition Tax Services

With increased activity in mergers and acquisitions (M&A) of businesses in both Singapore and the region, there is growing interest among potential investors in taking steps to make the M&A process more tax efficient. Potential investors are also looking into understanding the tax implications of acquiring businesses across various jurisdictions.

 

Tax Structuring

 

With increased activity in mergers and acquisitions (M&A) of businesses in both Singapore and the region, there is growing interest among potential investors in taking steps to make the M&A process more tax efficient. Potential investors are also looking into understanding the tax implications of acquiring businesses across various jurisdictions.

 

 

On acquisition:

  • Advise on the Singapore tax implications on the mode of acquisition (acquisition of shares vs asset)
  • Advise on the specific tax attributes of the target entity (e.g. preservation of tax loss items, etc.)
  • Advise on the Singapore tax implications of the funding strategy (e.g. capital injection vs loan)


On holding:

  • Advise on the tax efficiency of the proposed holding structure
  • Advise on the tax implications of income flows (i.e. dividend, interest), with reference to the relevant double taxation agreements, where applicable


On holding:

  • Advice on the tax implications of an exit of the investment including the possibility (and conditions) of Singapore tax exemption on such gains.
 

Recommendations:

  • Overall tax assessment of the proposed structure
  • Provide suggestions on alternative structures which may provide for more flexibility or better tax efficiency, where applicable.

 

 

Advise on applicable M&A related tax incentives

We help companies to leverage on existing M&A incentive schemes, which would help to provide for tax savings and optimise their post-acquisition tax position, as part of the strategic objectives of an M&A deal.

This would include an assessment of whether an investor can take advantage of the M&A Allowance Scheme, which provides for an allowance based on 25% on the value of acquisition (capped at S$40m), for qualifying share acquisitions from 1 April 2016 to 31 December 2025.

We will also assess the availability and applicability of other tax incentive schemes in the M&A planning process, such as those targeted at specific industries or activities, including the Global Trader Programme, Development and Expansion Incentive Scheme, Finance and Treasury Centre Incentive Scheme, or Maritime Sector Incentive – Approved International Shipping Enterprise Incentive Scheme.

 

Tax due diligence

Before finalising the M&A deal, it would also be prudent to perform a tax due diligence, which helps provide information on the tax risks and implications associated with the purchase and equips investors with more power in the negotiation process. Sellers may also wish to perform a tax due diligence to help assess the overall tax health of the business and make the necessary remedies to strengthen the chances of success of the M&A deal.

 

Our team provides holistic tax due diligence services, both buy-side and sell-side. As part of the tax due diligence process, we will help to assess the general compliance status in relation to tax filing and payment obligations, potential tax liabilities arising from any outstanding tax queries or audits, as well as estimate the potential tax impact arising from material tax adjustments.

Speak to our Specialist(s)

Edwin Leow

Director,
Head of Tax

Shaun Zheng

Director,
Tax

Speak to our Specialist(s)

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