Kwong Wing Leon
Partner | Singapore
Secretary Trizia May Dela Cruz
Operating as Withers KhattarWong LLP in Singapore.
Track record
Developing a tax efficient structure for a treasury hub
Advised Indorama Group, a multi-billion dollar global conglomerate and a leading manufacturer of various products across 37 jurisdictions, on developing a tax efficient structure for a treasury hub and investment of financial assets.
Over 20 transactions with a cumulative market value in excess of $4 billion
Acted as lead tax advisor to Pacific Alliance Group in over 20 transactions with a cumulative market value in excess of US$4 billion, in various asset classes, private equity, real estate, and alternative investments, from Singapore into Australia, Hong Kong, India, Japan, Korea, and New Zealand.
Norway and Singapore treaty
Assisted Norwegian counsel regarding the application of the Norway-Singapore treaty to dividends received by a Singapore-resident from Norway but not remitted to Singapore, where the Oslo court held that the limitation of benefit article was otiose since the income in question was exempt from tax in Singapore. Cf. Weisser v HMRC (2012) UKFTT 501 (TC).
Interest withholding tax
Obtained ruling that interest withholding tax did not apply to an equity kicker under a loan agreement only two days before client was to pay US$1.8 million in withholding tax on advice of a global law firm.
Canadian sovereign fund
Assisted a Canadian sovereign fund in obtaining tax-exempt status in Singapore.
Income Tax Act
Brought an appeal that obliged the Ministry of Finance to cause the Income Tax Act to be amended the day before the hearing in TM v Comptroller of Income Tax [2007] SGITBR 1.
Tax refund change of law
The successful outcome for the client in SUT Sakra Pte Ltd v Chief Assessor VRB Appeal No 300 of 2004 resulted in the law being changed to avoid the IRAS having to refund taxes to other taxpayers.