Koh Chon Kiat is a Partner in the firm’s Tax Practice. He advises on Singapore and cross-border tax matters, with particular focus on contentious tax disputes, complex tax structuring and high-value advisory work involving income tax, GST, stamp duty, property tax and interpretation of tax treaties. He regularly acts for multinational corporations, sovereign-linked entities, financial institutions, and ultra-high-net-worth clients.
Chon Kiat has a strong track record in helping clients resolve multi-million-dollar disputes with the Inland Revenue Authority of Singapore and is recognized for his ability to navigate technically complex and evolving areas of tax law, including cross-border structuring, treaty interpretation and indirect tax disputes.
Chon Kiat has been recognized as a “Rising Star” in Asialaw Leading Lawyers, reflecting strong client feedback, market reputation and the complexity of matters he handles.
EXPERIENCE
- Acted in Herbalife International Singapore Pte Ltd v Comptroller of GST [2023] SGHC 54, a landmark GST decision resulting in tax savings of approximately S$2.2 million and recognised as Impact Case of the Year by International Tax Review..
- Acted in Singapore Cement Manufacturing Co (Pte) Ltd v Comptroller of Income Tax [2023] SGHC 57, a High Court decision on capital allowances involving approximately S$13 million in dispute.
- Advised one of the largest infrastructure asset owners in Singapore on a complex property tax dispute concerning the annual value of a waste-to-energy facility, achieving recurring annual tax savings of approximately S$2.6 million.
- Acted for a sovereign-linked alternative asset manager anchored by a foreign government on permanent establishment risks and treaty issues arising from the proposed appointment of a Singapore-based consultant, advising senior management on practical restructuring solutions to mitigate cross-border tax exposure.
- Acted as Singapore tax adviser on international capital markets transactions, including the issuance of US$330 million convertible senior notes by a NASDAQ-listed multinational technology company.
- Acted for a wholly owned subsidiary of a Singapore-listed offshore and marine group in a significant income tax dispute with IRAS involving the deductibility of losses arising from bridging loans and the characterisation of interest income as trade income, resulting in a favourable resolution and substantial tax savings.
- Acted for a global alternative asset manager with approximately US$16 billion in assets under management on the applicability of Singapore fund tax exemption regimes to offshore fund structures, including the interpretation of statutory conditions and fund documentation.
- Acted for a multinational logistics and freight forwarding group headquartered in Europe on the Singapore tax implications of a cross-border notional cash pooling arrangement, advising on withholding tax, transfer pricing considerations, treaty interpretation, and permanent establishment risks.
- Acted for a prominent family-owned multinational group in relation to a broad range of Singapore and cross-border tax matters, including royalty structuring, transfer pricing, indirect tax implications of non-cash distributions, investment loss deductibility, and capital-raising transactions.
