GMT
Building a Pillar 2 Framework for a Major Tobacco Manufacturer
We advised a leading Indonesian tobacco manufacturer, subsidiary of one of the largest tobacco manufacturers headquartered in Stamford. The company operates extensive production and distribution networks, also forms a key part of the group’s global operations.
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Reframing a Permanent Establishment Allegation
We defended a prominent multinational consumer electronics company in a permanent establishment (PE) tax crime case, proving misidentification and reframing the issue as administrative, leading to a settlement without prosecution.
Testing the Limits of Transfer Pricing Rules
We represented a South Korean multinational logistics company in a TP dispute over a domestic restructuring, convincing the court that no compensation was required for the spin-off of its operations.
