Regional assistance on tax matters
in the ASEAN region

Fair Consulting Tax Pte. Ltd. (FCTSG) was established in 2021 as a member of Fair Consulting Tax Corporation (FCT) to provide regional tax consulting services, focusing on transfer pricing, to multinational companies. Our transfer pricing professionals assist you to solve transfer pricing matters in the ASEAN region.

Our Main Services

With FCT and Fair Consulting Group firms, FCTSG offers a range of tax consulting services to your company.

Transfer Pricing Consulting

  • Transfer pricing risk assessment
  • Transfer pricing benchmarking analysis
  • Transfer pricing planning
  • Transfer pricing policy development, implementation and operation
  • Transfer pricing documentation
  • Transfer pricing audit defense
  • Advance Pricing Arrangement (APA)/ Mutual Agreement Procedure (MAP)

International Tax Consulting (Japanese tax perspective)

  • Controlled Foreign Company Rules
  • Transfer Pricing
  • Corporate Restructuring
  • Global Tax Management

Risks & Solutions

  • Loss-making,
    low margin

    Loss-making or low-margin limited risk companies may be challenged by tax authorities. You need to identify special factors or review the transfer price through transfer pricing planning.

  • Royalty
    payment

    Royalty payment for the same technology/know-how for a long period of time may be challenged by tax authorities as the value of the intangible assets may not be properly assessed. A risk assessment should be conducted and determine the needs to review the license.

  • End-year TP
    adjustment

    Year-end transfer pricing adjustments may be challenged by tax authorities if the adjustments do not comply with the transfer pricing guidelines or transfer pricing documentation is not prepared. Since some countries do not allow the year-end transfer pricing adjustments, we recommend you consult with transfer pricing advisors before such adjustments.

  • No Preparation/
    update of transfer
    pricing documentation

    Many countries require transfer pricing documentation by the time for the making of the tax return every year, and non-compliance can result in penalties, including surcharges. To avoid non-compliance, annual updates and major updates every three years are required.

  • Service fee
    payment

    Service fee payment without benefits test, appropriate fee computation and deliverables may be challenged by tax authorities. We recommend you conduct a risk assessment and review the current transfer pricing policy, if necessary.

  • Loan interest,
    guarantee fee
    payment

    Loan interest/guarantee fee payment without proper evaluation of credit ratings of the borrower and the guarantor/guarantee may be challenged by tax authorities. We recommend you conduct a risk assessment and review of the current transfer pricing policy, if necessary.

  • New transactions
    with related parties

    New transactions may result in changes in function, risk and profit allocation. Non-arm's length pricing or profit margin may be challenged by tax authorities. We recommend you set price or profit margin based on transfer pricing planning.

Multilingual Audio Summary: Japanese Transfer Pricing Webinar

Transfer Pricing Fundamentals: Pricing (Intra-group Services, Intangible Assets, Financial Transactions, Price Adjustment)

We have conducted a webinar in Japanese that comprehensively covers the fundamentals of transfer pricing, focusing on the pricing of intra-group services, intangible assets, financial transactions, and price adjustments. The content is presented in clear and accessible language, consciously avoiding overly technical terminology to facilitate understanding among those new to the subject.

While the videos and materials are currently available only in Japanese, the underlying pricing principles are broadly consistent across jurisdictions worldwide. To support our international audience, we are providing AI-generated audio summaries in 14 additional languages.

Please click on the image to proceed to the registration form, where you can listen to the audio summaries in all available languages.

Please note that the audio summaries provided on this page are generated using AI technology. While we strive to deliver accurate and useful content, these AI-generated summaries may not capture all the details and nuances of the original Japanese webinar in full. They are intended as helpful aids for understanding the key points of the presentation but should not be considered comprehensive substitutes for the Japanese videos and materials. We appreciate your understanding and hope this resource enhances your learning experience.

  • Transfer Pricing Fundamentals: Pricing of Intra-Group Services

  • Transfer Pricing Fundamentals: Pricing of Intangible Assets

  • Transfer Pricing Fundamentals: Pricing of Financial transactions

  • Transfer Pricing Fundamentals: Price Adjustment

Contact Us

FAIR CONSULTING TAX PTE. LTD.

6 Raffles Boulevard, Marina Square, #03-308, Singapore 039594

Naoki Shimokawa
Regional Director

After experiencing product localization, marketing and foreign subsidiary management, Naoki started his career in transfer pricing in one of the largest Japanese entertainment company. Naoki worked for Deloitte Japan and Singapore from 2013 to 2021 and provided transfer pricing advisory services to various clients as a transfer pricing specialist utilizing his experience in business firms.
Naoki joined Fair Consulting Tax Pte. Ltd. as a Regional Director (International Tax) in February 2021 and provides regional tax advisory services from Singapore, mainly transfer pricing, in the ASEAN region.

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