Insights
Real Cross-Border Problems. Structured Solutions.
Case Study 01
Reducing Indirect Tax Leakage in a Cross-Border Support Model
The Challenge
A group with limited indirect tax recovery on purchased services operated an overseas entity under a cost-plus intercompany model, creating irrecoverable indirect tax leakage. The business needed a structure supporting legitimate cross-border operations while reducing unnecessary costs — without creating misalignment between contractual arrangements, transfer pricing principles, and compliance expectations across jurisdictions.
My Approach
Operational mapping of what the support team actually does — functions, decision-making, supervision, and deliverables — and where the benefit of those services is used and consumed.
Indirect tax analysis of current intercompany flows to identify which charges create irrecoverable tax, why, and a high-level quantification of the leakage based on available facts.
Re-design options including re-scoping the support entity’s role, adjusting contractual flows, and re-aligning the operating model so that transfer pricing, indirect tax, and documentation tell one coherent story.
Implementation support covering intercompany agreements aligned with the operating reality, a transfer pricing policy narrative consistent with the indirect tax position, and evidence and documentation priorities to support the model under review.
Outcome
A short set of workable structuring options with clear trade-offs, an explanation of the leakage mechanism, and an implementation plan designed to keep indirect tax, transfer pricing, and contracts aligned over time.
Case Study 02
Strategic Guidance for a Singapore Holding & Operating Structure
The Challenge
A founder-led group operating through a Singapore Pte. Ltd. as part of a wider cross-border structure needed high-level strategic guidance to ensure the corporate setup remained practical and compliant, while keeping future flexibility for restructuring and mobility. The group wanted a thought partner to evaluate and align multiple moving parts across jurisdictions — corporate governance, ongoing compliance, restructuring pathways, intercompany financing, asset transfers, dividend strategy, and corporate mobility planning.
My Approach
Structure mapping and objectives: clarified business goals, decision timeline, and which jurisdictions and entities were in scope; mapped current ownership, control, cash flows, and contractual relationships at a high level.
Governance and compliance baseline: identified governance and operational requirements for the Singapore entity including board, substance, and documentation discipline; outlined the compliance posture needed to support the structure in practice.
Planning workstreams: reviewed intercompany financing and cash movement options including dividend considerations; considered asset transfer and relocation pathways including sequencing and documentation priorities; developed a short list of workable structuring and restructuring options with clear trade-offs and risk boundaries.
Implementation roadmap: produced a practical action plan coordinating corporate steps, documentation, and stakeholder responsibilities; identified where local counsel or specialists were needed for jurisdiction-specific execution.
Outcome
A structured set of planning options and an implementation roadmap designed to keep corporate governance, cross-border structuring, and compliance aligned over time — supporting decisions that can stand up to scrutiny as the group grows and evolves.
Every Engagement Starts With the Facts as They Are.
Recommendations are tested against operational reality before they are presented. Trade-offs are named clearly.