Cross-border tax, transfer pricing and group reporting
Tax residence, substance, treaty claims, transfer pricing and group reporting for Singapore companies inside international groups. The questions most providers leave to someone else.
What's included
Residence and substance reviewWho decides what, where, and whether the evidence supports Singapore residence.
Board governance designMeeting calendar, authority matrix and minutes that show where decisions are made.
Certificate of residenceApplications prepared and renewed, with the substance file behind them.
Treaty claimsThe paperwork overseas payers need to apply treaty rates.
Transfer pricingIntercompany agreements, benchmarking and Singapore documentation.
CbCR, master file and Pillar TwoThresholds checked, filing responsibilities mapped, deadlines set.
Dividends and repatriationThe tax cost of each way to move money, compared before you decide.
Coordination with overseas advisersOne shared calendar so filings in every country use the same numbers.
What you receive, and when
| Substance and residence review report | 3 to 4 weeks |
| Governance pack: calendar, authority matrix, minute templates | With the report |
| Certificate of residence application | As required |
| Transfer pricing documentation | By the tax return due date |
| Annual group filing calendar | Every year |
What we need from you
- Group structure chart and intercompany agreements
- Board minutes and resolutions for the last two years
- Where each director and senior manager is based
- Related party transaction listings
How it works
A fixed fee for the initial review, agreed before we start. Ongoing upkeep (calendar, certificate renewals, documentation) on an annual retainer.
Who it's for
Questions clients ask
Is a nominee director enough to make our company Singapore-resident?
Not for a foreign-owned investment holding company seeking a certificate of residence from 2025 onwards. IRAS looks for a Singapore-based executive director who is not a nominee, a key employee, or management by a related Singapore company.
Can another country treat our Singapore company as its tax resident?
Yes, if the company is in substance managed from there. India's place of effective management test is a common example. The answer is governance and evidence, not paperwork.
Does our Singapore subsidiary file CbCR in Singapore?
Not if the group is headquartered elsewhere. Singapore CbCR applies to Singapore-headquartered groups with revenue of at least S$1,125 million. Pillar Two registration may still apply.
Do you file overseas returns?
No. Licensed advisers in each country file there. We coordinate so the numbers and the story are the same everywhere.
Know before you start
POEM and substance: when India can tax your Singapore company, and why positions fail
Two tax authorities ask the same question from opposite ends. India asks whether your Singapore company is really run from India. Singapore asks whether it is really run from Singapore. You need the right answer for both.
7 min readCross-border tax & transfer pricingCertificate of residence for India-owned Singapore companies
What IRAS checks, what India asks for under the new Income-tax Act, and why a nominee director alone no longer gets a holding company its certificate.
4 min readCross-border tax & transfer pricingCbCR, master file and Pillar Two for Indian groups with Singapore subsidiaries
The group-level transfer pricing filings that catch Indian finance teams out, with the new form numbers under the Income-tax Act, 2025, and what the Singapore subsidiary must do.
4 min readOther services
Tell us what you need.
We reply with what applies to you and a fixed-fee proposal.