GMT
Implementing a Pillar Two Framework for Global Tax Readiness
We advised a leading Indonesian tobacco manufacturer on building a Pillar Two framework under PMK 136/2024, modeling effective tax rates for 9 entities to ensure operational readiness.
More Stories
Resolving a Complex Permanent Establishment Risk
We represented a prominent multinational consumer electronics company facing a Permanent Establishment (PE) tax inquiry. By reconstructing the economic facts and clarifying the legal framework, we successfully guided the case toward an administrative resolution, eliminating criminal exposure and securing a favorable settlement.
Assessing Transfer Pricing Rules in Corporate Restructuring
We represented a South Korean logistics multinational in a TP dispute, successfully securing a tax court ruling that domestic restructuring did not require business transfer compensation.
