Samantha Tan

Samantha advises on Singapore and international tax matters for multinational corporations (MNCs) and Singapore-headquartered companies. She regularly advises on the structuring of domestic and cross-border transactions, with an emphasis on global reorganisations, mergers and acquisitions, intellectual property migration, supply chain management, financing arrangements, and fund structures.

Samantha also specialises in providing comprehensive solutions to indirect tax issues faced by MNCs.

• Advised a global technology company on both direct and indirect tax implications of holding significant infrastructure assets in-country (e.g., network equipment and servers, subsea and land cables etc.) or obtaining operational support (e.g., colocation services) under various proposed arrangements. This project covered around 20 jurisdictions in the Asia Pacific region.
• Advised one of the world’s largest multinational technology companies on the (i) indirect tax implications on the sale of digital content and services to end-users in the Asia Pacific region, and (ii) direct tax and transfer pricing considerations with respect to owning and operating significant data centers in the local jurisdictions.
• Represented one of the world’s largest multinational technology companies in a Japanese advance pricing arrangement and currently working on advance pricing arrangements between Singapore and each of Malaysia and Thailand.
• Advised a global materials engineering and manufacturing company on tax incentives, various internal transactions and intellectual property, in light of the implementation of Pillar 2. 
• Represented an international private equity investment company with the purchase of a commercial real estate in Singapore.
• Advised a global technology company on the (i) tax characterisation and Singapore income tax implications of the fair value gains in relation to virtual power purchase agreements (VPPAs) entered into by a Singapore company, and (ii) goods and services tax (GST) implications of the settlement amounts under the VPPAs.
• Advised a publicly listed multinational travel technology company on the Singapore GST implications arising from its various business models and the use of virtual credit cards.
• Advised a publicly listed multinational medical devices and healthcare company on various internal restructurings, including financial arrangements, in light of the implementation of Pillar 2. 
• Advised a US publicly listed client in the cloud computing industry on the implementation of its distribution structure in Asia Pacific. This involved advising on income characterisation, withholding tax and transfer pricing issues.
• Assisted a major client in the human capital industry in designing, implementing and coordinating the expansion and restructuring of its Asia-Pacific, Middle-East and Africa operations across 14 jurisdictions. This required a consideration of tax, corporate, employment and intellectual property issues relating to the structure.
• Advised a world leader in exportation of raw materials on issues relating to the structuring and reporting of complex compensation packages, including pension and bonus benefits, across several jurisdictions. This involved employment, corporate and individual income tax and business considerations.
• Provided structuring advice for fund vehicles in Singapore on structuring for tax efficiency including qualifying for tax exemption or incentives, including both for private wealth clients, and also for funds, private equity funds and hedge funds.
• Advised a major REIT in planning an optimal tax-efficient structure for its commercial real estate investments in the UK and Europe.

• Singapore Academy of Law - Member
• Law Society of Singapore - Member