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Foremark Global / Services / Phase 3 · Tax
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Intelligence
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Services · Phase 03 of Six

The highest-value
phase in the engagement.

International tax structured incorrectly at entry costs far more to unwind than it costs to get right from day one. Phase 3 designs your group structure, transfer pricing policy, treaty optimisation, and repatriation architecture before a single dollar crosses a border.

03
Phase 03
$22,000
Per corridor · structure-dependent
Runs parallel with Phase 2
Group HoldCo and OpCo structure design
Transfer pricing policy (all intercompany flows)
Treaty network analysis and WHT minimisation
Repatriation architecture (India/UAE/Singapore)
Formal tax opinion letter from in-market counsel
Start this phase →
What Phase 3 designs

Six tax decisions.

Made correctly from the start.

Phase 3 covers six inter-related tax decisions. Made wrong, they compound against you for years. Made right, they become structural advantages.

🏢
HoldCo and OpCo Design
Where entities sit in the group, how they relate, and what that means for capital flows, tax efficiency, and eventual exit.
📊
Transfer Pricing Policy
A documented TP policy for all intercompany transactions — management fees, royalties, loans, shared services — compliant with the arm's length standard.
⚖️
Treaty Network Analysis
Every DTAA applicable to your corridor mapped against your actual payment flows. WHT rates on dividends, interest, and royalties identified and minimised.
💰
WHT Minimisation
Payment routing designed to legally apply treaty benefits at every node — the difference between 5% and 20% withholding tax on your repatriated profits.
🏦
Repatriation Architecture
How capital gets home from India (FEMA-regulated), UAE (free), and Singapore (free). Sequenced, structured, and planned before the first dollar is invested.
📃
Tax Opinion Letter
A formal written opinion from Foremark's in-market tax counsel on the structure taken — designed for board and investor due diligence.
Tax
Tax by corridor

Corridor-specific.

Not generic.

The tax architecture for India is completely different from UAE or Singapore. Foremark designs for the specific corridor with no generic assumptions carried over from other markets.

🇮🇳 India
India Tax Structure
25% WOS corporate tax · FEMA transfer pricing · MAT exposure management · DTAA WHT reduction to 5–10% · PLI/SEZ incentive integration.
25%
🇦🇪 UAE
UAE Tax Structure
0% QFZP on qualifying free zone income · 9% mainland · No CGT · No dividend WHT · HoldCo structuring for MENA/India investments.
0–9%
🇸🇬 Singapore
Singapore Tax Structure
17% standard · Pioneer Status reduces effective rate significantly · Foreign-sourced income exemption · 90+ DTAA treaties.
17%
How Phase 3 runs

Four steps.

Four weeks.

Phase 3 runs in parallel with Phase 2. The group structure memo is produced first and directly informs Phase 2 entity design.

01
Weeks 6–8
Group Structure Design
HoldCo placement and OpCo structure decided before any incorporation — the structure memo Phase 2 executes against.
02
Weeks 8–10
Treaty & WHT Mapping
Every applicable treaty benefit mapped against your intercompany payment flows. WHT minimisation strategy documented.
03
Weeks 9–11
Transfer Pricing Policy
Intercompany pricing policy drafted. APA pathway identified where applicable. TP file structure agreed.
04
Weeks 11–12
Tax Opinion Letter
Formal tax opinion from in-market tax counsel. Board-ready documentation of all positions taken.
✦
Start Phase 3

Your tax architecture,
designed before entry.

Phase 3 is the phase most companies skip and most regret. The cost of fixing a poorly-designed structure post-entry consistently exceeds the Phase 3 fee many times over.