GMT
Structuring Transfer Pricing for the Functional Beverage Sector
We assisted a Japanese multinational health beverage manufacturer in designing a sustainable transfer pricing framework for goods, services, and royalties while managing PE risks.
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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.
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.
