Finance Legal Tax Green Technical Intelligence

“Tax issues considered early and woven into the design of the structure or transaction are no longer issues.”

Tax advice matters most when it is connected to the business model. Cross-border investments, acquisitions, financings and restructurings all create tax consequences that affect cashflow, valuation, documentation and execution. If those consequences are identified too late, they become leakage, exposure or dispute.

Our tax practice aligns tax strategy with commercial goals, legal structure and financial reality. We do not approach tax as a standalone opinion. We assess how the structure works in practice: where profits are earned, how funds move, how parties contract, how obligations are reported and how the position can be defended if challenged.

Working with experienced Indonesian and international tax advisers, we support market entry, corporate structuring, transfer pricing, mergers & acquisitions, due diligence, audit defence and dispute resolution. Our objective is simple: clear, practical tax advice that protects value, reduces surprises and fits the transaction.

Our Services

Tax Structuring and Transaction Support

Market entry and corporate tax structuring. Aligning business models, investment structures and tax strategies to minimise inefficiencies and surprises.
Mergers & Acquisitions tax due diligence. Identifying historical exposures, ongoing obligations and transaction tax consequences.
Transaction modelling and implementation. Building tax consequences into financial models, legal documents and cashflow planning.
Cross-border and investment structuring. Designing practical structures for foreign investment, financing and repatriation.
Personal and corporate tax planning. Supporting tax planning for individuals, shareholders, companies and operating groups.

Transfer Pricing and Conflict Resolution

Transfer pricing strategy and documentation. Supporting purchases, sales, services, royalties and financing arrangements with defensible analysis.
Audit defence and dispute resolution. Defining strategy and supporting taxpayers through audits, objections and appeals.
PE and WHT. Assessing permanent establishment risk, withholding tax exposure, contract structures, service arrangements and treaty positions.
Customs and regulatory alignment. Ensuring tax positions are consistent with customs, investment and operating requirements.
Active tax management. Early identification of exposures and opportunities before they become disputes.

Key Persons

Graham Garven

Senior Tax Consultant

Graham has over 30 years’ tax experience, including 25 years in Indonesia, and is widely regarded as one of the country’s leading foreign tax advisers. Formerly a Partner at KPMG Indonesia, he established its award-winning Transfer Pricing practice. His expertise spans transfer pricing, dispute resolution, mergers & acquisitions, and cross-border structuring across sectors including financial services, FMCG, and aviation. A Chartered Accountant with a Master’s degree from the University of Aberdeen, Graham is now based in Scotland supporting international stakeholders and Indonesian operations.