International Tax Search
Retained search for international tax partners and teams leading cross-border structuring, BEPS Pillar Two implementation and treaty and withholding tax advisory from the Singapore and Hong Kong hubs.
Market overview
International tax is the discipline most directly reshaped by BEPS 2.0, and in Singapore and Hong Kong it is the single hottest seat in the market. Both jurisdictions brought the 15 percent global minimum tax into force for financial years beginning on or after 1 January 2025 - Singapore through the Multinational Enterprise Top-up Tax and Domestic Top-up Tax under the Multinational Enterprise (Minimum Tax) Act 2024 [1], and Hong Kong through the Income Inclusion Rule and the Hong Kong Minimum Top-up Tax [2] - for in-scope groups with turnover above EUR 750 million. Every such group needs partners who can model effective tax rates jurisdiction by jurisdiction, design compliant structures and run the GloBE Information Return process, and there are nowhere near enough of them in the region.
Singapore and Hong Kong are the natural home for this work because they are Asia's regional headquarters and holding hubs. Singapore remains a leading regional-headquarters hub for multinationals across Asia-Pacific and Hong Kong's count of regional headquarters reached about 1,510 in 2025 [3]; Hong Kong's foreign-sourced income exemption (FSIE) regime, covering foreign dividends, interest, IP income and disposal gains received by MNE-group members, makes structuring and substance advice central to every cross-border mandate [4]. Deep treaty networks on both sides reinforce the demand.
The work spans more than Pillar Two. Cross-border structuring, treaty analysis, withholding tax management and the interaction of all of these with a group's wider footprint require partners who hold the field in their heads. Crucially, transfer-pricing policy now directly feeds the GloBE tax-base calculation, so leading firms increasingly want international tax leaders who can sit across both disciplines rather than treat them separately.
The regional markers of genuine cross-border capability are the SCTP Accredited Tax Advisor (Income Tax) in Singapore and HKICPA standing in Hong Kong, typically paired with the ADIT, the Chartered Institute of Taxation's Advanced Diploma in International Taxation [5], as the secondary international credential. Partners with a Pillar Two delivery record are among the most search-active profiles in the market, and these moves run almost exclusively through retained, confidential processes.
What we cover
- Cross-border structuring
- BEPS / Pillar Two
- Treaties & withholding tax
Roles we place
Cross-Border Advisory
- International Tax Partner
- International Tax Director
- Cross-Border Structuring Lead
- Senior Manager, International Tax
Pillar Two & Tax Reform
- Pillar Two / BEPS Partner
- GloBE Reporting Director
- Global Minimum Tax Lead
- International Tax Reform Manager
Treaty & Withholding
- Treaty & Withholding Tax Specialist
- International Tax Counsel
- Inbound / Outbound Tax Director
Candidate profile
SCTP Accredited Tax Advisor (Income Tax) in Singapore or HKICPA membership in Hong Kong as the regional markers, paired with the ADIT (Advanced Diploma in International Taxation) as the leading cross-border credential and, for treaty and structuring work, a law degree.
Demonstrated BEPS Pillar Two implementation and GloBE / GIR delivery experience.
Big Four international tax desk, major law firm or in-house regional headquarters pedigree in Singapore or Hong Kong.
APAC regional reach and languages (Mandarin, Cantonese, Japanese, Bahasa) valued for holding-company and inbound work.
Seniority
- Senior Manager
- Director / Associate Director
- Partner / Principal
- Head of International Tax
Sectors served
- Multinational holding & headquarters structures
- Financial services & funds
- Technology & digital
- Energy & resources
- Pharmaceuticals & life sciences
- Consumer & industrial groups
Frequently asked
- Why is international tax hiring so competitive in Singapore and Hong Kong right now?
- Both jurisdictions brought Pillar Two into force from 1 January 2025, so every multinational above the EUR 750 million threshold with a Singapore or Hong Kong presence now needs partners who can model global minimum tax exposure and run GloBE reporting. That capability was scarce before the rules went live, and as the region's headquarters and holding hubs the two cities concentrate the demand. Firms are hiring to build benches faster than the market can produce them.
- Do you look for ADIT specifically?
- We lead on the SCTP Accredited Tax Advisor in Singapore and HKICPA standing in Hong Kong, then treat the ADIT as the clearest signal of genuine cross-border depth. We weigh those alongside a Pillar Two delivery record and client portability rather than treating any single credential as a gate.
- Can you combine international tax and transfer pricing in one search?
- Yes, and increasingly clients ask for exactly that, because transfer-pricing policy now flows directly into the Pillar Two tax base. We regularly run mandates for partners who span both disciplines across the Singapore and Hong Kong hubs.
Sources
- [1]Pillar 2 Top-up Taxes (GloBE / MTT / DTT) - IRAS Singapore
- [2]Global minimum tax and Hong Kong minimum top-up tax - IRD Hong Kong
- [3]Hong Kong as a Regional Headquarters Hub - Woodburn Accountants & Advisors
- [4]Foreign-sourced Income Exemption (FSIE) - IRD Hong Kong
- [5]ADIT international tax - Chartered Institute of Taxation