Corporate Tax Considerations for Software Licensing Arrangements

Richard Goh is a Group Tax Specialist at the Inland Revenue Authority of Singapore, with over 15 years of experience in tax policy, compliance, and advisory. As a Chartered Valuer and Appraiser and a Certified Master Tax Specialist in Intellectual Property (IP), Richard brings a unique blend of expertise in tax, IP, and valuation particularly in advising on complex transfer pricing and valuation issues involving acquisitions and transfers of IP and other intangibles across various sectors.

He also serves as a Curriculum Development Specialist at the Tax Academy of Singapore, where he designs and delivers specialized programs to build deep capabilities among tax professionals. A passionate educator and thought leader, Richard frequently speaks at seminars and workshops, advocating for stronger collaboration between the tax, IP, and valuation communities. He has published works on the valuation and transfer pricing of intangibles and is a member of the Standards and Technical Working Group under the Institute of Valuers and Appraisers Singapore, contributing to the development of valuation standards and best practices.

Chun Ying is a Senior Partner in the Tax and Trusts, Estates and Wealth Preservation Practice and is the Head of Tax practice of Dentons Rodyk. 

Chun Ying is a tax lawyer based in Singapore with more than a decade of experience advising and representing multinational corporations and individuals on a broad range of cross-border tax issues, as well as tax disputes. Chun Ying's practice covers all aspects of Singapore taxes including income tax, stamp duty, goods and services tax, and transfer pricing. She is also well-versed in regional and global tax issues, having worked on many multijurisdictional tax matters.

Chun Ying has worked with a diverse range of clients, ranging from large Fortune 500 and listed corporations to startups, blockchain companies, real estate developers, funds, family offices, and high net worth individuals. Her noncontentious experience includes corporate restructuring, IP restructuring, M&A, tax incentives, blockchain and ICOs, fund structuring, startup ESOPs/founder shares planning and many others.

On the contentious side, Chun Ying has appeared before administrative tribunals and has represented many taxpayers in audits and objections before the tax authorities. Controversy issues she has handled include tax incentive disputes, IP writing-down allowances, taxation of revenue/capital gains, sourcing of income, deduction of R&D expenses, tax residency, payment characterisation issues, foreign tax credit claims, transfer pricing, GST registration obligations and many others.

Prior to joining Dentons' practice, Chun Ying was a partner at a tier-one tax practice of an international law firm, where she built a career advising and representing clients in a range of highly complex tax matters. She also has a unique background having served as the APAC Senior Tax Counsel of Visa Worldwide Pte. Ltd., a top Fortune 500 company that operates in more than 200 countries globally.

Chun Ying is ranked Up and Coming Partner for Tax by Chambers, as well as Next Generation Partner by The Legal 500. She is recognised as Notable Practitioner for Tax by asialaw. Chun Ying was also awarded "Tax Lawyer of the Year" for Asia Pacific, in the Women of Business Law APAC Awards for 2023, and was shortlisted "Tax Disputes Lawyer of the Year" for 2022.

Kok Leong is Head of the Firm’s Technology & Corporate Intellectual Property Practice, and his area of expertise spans technology, Artificial Intelligence & emerging technologies, electronic transactions, online platforms, intellectual property, data protection, cybersecurity, franchising, e-commerce and outsourcing transactions and projects as well as contractual collaborations. 

He has over 30 years’ experience in advising on, negotiating and drafting a wide range of commercial agreements related to intellectual property and IT, data protection and data privacy, cybersecurity, e-commerce, Financial Technology (FinTech), outsourcing, franchising, licensing, merchandising, contractual collaborations and joint ventures, telecommunications, consultancy services, hotels and hospitality, distributorships, agency, supply and service arrangements, contract manufacturing, technology transfers, research and development, sports, online gaming, media and publishing, entertainment, on-line gaming, cloud services and streaming services.

Annie Pan is an experienced tax leader, she has leveraged her extensive experience in tax management and international taxation to provide strategic guidance and support to the organization. With over 20 years of experience in the field, she has developed a strong expertise managing the tax function with a proven track record in her career with some of the US based MNC with both regional and global exposures. She is currently the Head of Tax for Riot Games APAC. Annie is a qualified CPA of Australia, and obtained her Master of Tax and MBA degree from UNSW.

Annie Pan has been elected as the President/Board member of Asia Chapter of Tax Executive Institute since 2025. Tax Executives Institute (TEI) is a diverse, inclusive member-based organization, dedicated exclusively to the professional needs of the in-house tax community worldwide. TEI educates, networks, and advocates on all aspects of business taxation. As a well-respected industry leader, the Institute possesses unrivaled practical experience and is uniquely positioned to help organizations navigate the ever-changing global tax environment. TEI Asia Chapter has formed partnerships with various institutes and professional bodies such as IFA and Tax Academy of Singapore. As the president of Asia Chapter, Annie has represented her chapter members across Asia to proactively promote TEI and engaged in advocacy with various authorities (such as OECD, IRAS, EDB, MOF) on behalf of TEI members.

Mark is a Director and Chief Legal Counsel at IPOS. He also leads a team at IPOS which looks into how to position Singapore as a preferred jurisdiction for the resolution of IP and technology disputes.

He has 30 years of experience in IP law. Prior to joining IPOS in 2010, Mark was a lawyer in private practice for 15 years. 

Mark is an Adjunct Professor at the NUS Faculty of Law, where he co-teaches a module on IP Arbitration. He has published many articles in both local and international law journals, and is a co-author of the chapter on Copyright in Halsbury's Laws of Singapore: Volume 13(3) - Intellectual property (2007 & 2018 Reissue, Lexis-Nexis, Singapore). At IPOS International (a wholly-owned subsidiary of IPOS), Mark oversees the development and curation of training programmes in the area of IP law for the legal community and IP professionals.