We have specialists in international taxation which help Multi-national companies manage their multiple tax jurisdictions and complex business transactions with ease and certainty. With our creative thinking and hands on experience on structuring of variety of cross border transactions, we ensure client’s success in tax issues.

• Advisory and Issue of opinions on International Tax issues including Permanent Establishments, Royalty, Technical Know- How, Independent Personal service, Expat Salary, Subvention, etc
• Advisory on Double Taxation Avoidance Treaties including withholding tax issues, Tax Information Exchange Agreements
• Transfer pricing diagnosis, structuring, planning, ALP determination, benchmarking, and documentation (including Pricing /Revenue Sharing / Royalty / Know-how / Intangibles / Intellectual property rights/ Cost allocation arrangements/ AMP/Capital structuring & restructuring/ECB/Corporate Guarantee etc)
• Structuring Group Contract Arrangements for instance Secondment of employees, Pricing Strategies for goods and services, Intangible Assets, Inter group capital financing arrangement etc for Multinational Groups in tax efficient manner compliant with International Taxation and Transfer Pricing laws.
• Cross border transaction advisory including advising inbound and outbound investment strategies, optimum ownership structures, optimal entry and outbound investment vehicle, holding co jurisdiction, capital structuring to achieve optimal repatriation, advising all modes of inbound and outbound investments FDI/FII/JVs/Venture Capital Funds/ Foreign Collaborations’/PE, GDR, FCCBs etc
• Developing tax efficient inbound and outbound structures for MNCs and assisting them in setting up base and expansion of businesses including low tax jurisdictions like Mauritius, BVI, Singapore, Dubai, Bahamas, Cayman Island etc
• Representation before, TPO, AO, CIT(A), DRP, AAR, Income Tax Appellate Tribunal including safe harbour representation, Advance Pricing Arrangement (APA), MAP etc
• Place of effective management planning, documentation and reviews
• Review and drafting of agreements for the group
• Regulatory & Compliance services for instance 3CEB filing, Country by country Reporting, 15CA & 15CB filings, Obtaining Nil/ lower withholding Tax Certificates etc
• Advisory and representation on General Anti Avoidance regulations