Salil Goyal

Manage all tax compliance and advisory for direct. indirect tax and transfer pricing projects accross EMEA and SEA

Transfer Pricing

A) Developed transfer pricing (“TP”) documentation for 100+ clients across multiple sectors

• Served large and medium sized clients across 13 major sectors including Real Estate, Automotive, Infrastructure, Energy, Telecom, IT, Commodities, Chemicals, Metals & Others

• Designed a robust policy for Regional Cross Charges, Group Royalties and Segmentation set up for a local conglomerate with complex manufacturing and distribution supply chain

B) Advised and implemented operational TP for:

• A listed cement company in Indonesia (gap assessment in transactions pricing policy, streamlined transactions/invoice flows in accordance with the substance and FAR, and centralized the remuneration model for manufacturing, distribution and IP/trademark)

• Jakarta based technology co. to consolidate the various marketplace apps into a super app

• UK/Singapore based tobacco co. to facilitate contract R&D alongside contract manufacturing

• Indonesia based oil and gas company involving special tax regime

• An Oleochemical company facing capacity utilization

Business Restructuring

• Advised on a sale and lease back deal of on oil drilling rig between BVI and Norway

• Optimized pricing model for a major real estate company involved in trading of building materials and property development through free trade zone and mainland entities

• Advised on restructuring operations of a contract manufacturer of crumb rubber based on economic substance, FAR and relevant index regulations used for sales and intercompany pricing

• ESG Impact analysis for a major MNC group involved in coal mining

• Advised on resolution of tax disputes of a Singapore based medical equipment distributor

• Resolved tax disputes of a commodities company facing manufacturing losses

• Advised on resolving tax issues related to multiple contract manufacturers and distributors

• Webinars on above tax issues

• Formalized the tax process manual to effectively manage branches/subsidiaries in 35+ countries

• Led the India GST implementation projects including guiding ERP preparedness

• Conceptualized tax efficient structuring of outbound secondments inc: a) risk / impact analysis of split payment structure and b) analysis based on social security treaties of India with select nations

• Created tax policy for a new fintech company promoted by the group in UAE: a) Developed global TP policy for invoices b) Minimum Economic substance policy to be maintained to avail free trade zone benefits c) Impact analysis on WHT and VAT for sales from UAE Freezone to other GCC and foreign countries d) Advise on free trade zone and mainland entity for intl. and local ops

• Developed an in-house research / consulting team in India for global benchmarking to reduce dependence on outside consultants with cost savings of ~$40K per annum

• Led tax due diligence for multiple M&A opportunities pursued by the Group (2 successful)

Dispute resolutions and Tax refunds

• Resolved long standing litigation tax cases pertaining to permanent establishment and audit issues in Europe and Africa with ~$7M positive impact

• Led a special cross country project team for availing the first service tax refund of $2M and direct tax refund of $1.4M in India

Effective Tax Rate (ETR) Improvement

• Led a special project for entity optimization (including M&A / divestitures within Group) to improve the group ETR from 37.8% to 33.7%, resulting in tax savings of $1.1M

• Intellectual Property migrations within Group entities to drive for improving tax credit utilization resulting in improved ETR and tax savings of $300K

• Led a project team for claiming R&D incentives for new products in India ($1.3M tax savings)