Photo, Allen Tan

Allen Tan

Principal
Wong & Leow LLC

Biography

Allen Tan is the head of the Tax, Trade and Wealth Management practice in Baker McKenzie Wong & Leow. He has extensive experience working on both international and local tax issues, with a special focus on the regional tax aspects of the transactions that he is involved in. Allen’s clients include Global Fortune 500 multinational corporations and major Singapore conglomerates. He is recognised as a leading lawyer for his tax controversy and corporate tax work in many leading legal and tax directories including International Tax Review, Chambers Asia Pacific and Legal 500 Asia Pacific. Allen was also named the Asia Tax Practice Leader of the Year 2018 by International Tax Review.

Practice Focus

Allen focuses on tax issues arising from corporate and supply chain reorganisations, foreign direct investments, cross-border planning/restructuring, transfer pricing, mergers and acquisitions, private equity fund structuring, tax controversies (both domestic and cross-border), as well as indirect and transfer taxes. In recent years, Allen has also been actively engaged in tax policy work, both in Singapore and internationally.

Representative Legal Matters

  • Assisted a major Asian conglomerate with its corporate transformation exercise which involves consolidating its multiple business lines. The project spans 22 countries with 165 entities globally and takes into account significant global developments such as BEPS, US tax reform and Brexit.
  • Assisted one of the world's largest global multinational technology company in restructuring its key operations following US tax reform and changes introduced in various jurisdictions, including Singapore, in light of OECD's BEPS project. Allen advised the company in navigating various novel and untested tax legislation, including engagements with various governmental authorities.  
  • Successfully represented one of the biggest companies in the world in a tax dispute with the Inland Revenue Authority of Singapore over the application of tax incentive laws. The dispute raised a number of important issues, such as the scope of the applicable tax incentives, the interpretation of the relevant legislation, and even constitutional law issues concerning exercise of discretion under tax laws.
  • Assisting a major oil and gas company with its joint venture arrangements for the extraction, production and sale of natural gas. Allen advised the company on various aspects of the joint venture arrangement, including the planning and setting-up of the financing and sales structure, the functions and activities the various parties involved, while taking into account regional tax considerations and the transfer pricing policy for the group.
  • Assisted a leading technology company that is widely recognised as an industry leader with its strategic joint venture in China. As the joint venture arrangement was complex, and involved the transfer of technology, Allen advised the company on a range of diverse tax issues, while taking into account business/commercial realities of the transaction, the dynamics between the parties, the regulatory issues and considerations as well as providing holistic, commercially astute and innovative advice to the company.
  • Advised a leading operator of an online marketplace on a potential expansion of its business lines as well as the identification and mitigation of its permanent establishment risks across 13 Asia Pacific jurisdictions. Allen explored a number of potential business models and provided detailed advice on the direct and indirect tax implications of the ideal models for each of the 13 jurisdictions under review.
  • Advised one of the world's largest technology companies with the restructuring of its IP holding structure. The project is particularly complex due to the historical relationships and transactions spanning multiple jurisdictions. Allen assisted the company in navigating a wide range of novel and complex issues, including IP law and commercial arrangements, which draw upon Allen's experience in handling legal, accounting and transfer pricing issues.
  • Representing a US-listed multinational corporation in an ongoing appeal before the Singapore High Court against the disallowance of the deduction of R&D expenses under a cost-sharing agreement. This case is the first of its kind to be litigated in Singapore.
  • Advised a global luxury brand on restructuring its global transfer pricing model, and on the key design considerations of a new sustainable model. Allen assisted the company with planning, risk assessment/management as well as pro-active dispute resolution measures such as advanced pricing arrangements.
  • Assisted a global e-commerce and technology company with setting-up a strategic logistics and warehousing hub in the APAC region. Allen had to advise on a complex and highly elaborate supply chain which involved a network of entities engaged in activities ranging from product selection and placement, order confirmation, procurement and storage as well as the order delivery and fulfilment.

Professional Associations and Memberships

  • Bar of England and Wales - Member
  • Singapore Academy of Law - Member
  • Law Society of Singapore - Member
  • Middle Temple Inn of Court - Barrister
  • International Fiscal Association (Singapore branch) - Chairman 
  • Singapore Institute of Accredited Tax Professionals (SIATP) - Accredited Tax Practitioner (Income Tax & GST)
  • Singapore Institute of Accredited Tax Professionals (SIATP) - Tax & Levies Committee Member
  • Bar of Malaysia & Kuala Lumpur - Member

Admissions

  • Singapore
  • England & Wales
  • Malaysia

Education

  • University of Sheffield
  • National University of Singapore
  • Nottingham Law School

Languages

  • Chinese
  • English
  • Malay

Previous Offices

  • Kuala Lumpur