Expert Legal, Businesssetup, Accounting & Financial, International Taxation, Transferpricing Consulting Services in India,

International Tax Planning and Advisory

Structuring cross-border transactions, investments, and joint ventures to minimize tax liability, Structuring cross-border transactions, investments, and joint ventures to minimize tax liability. 

• Cross-Border Tax Planning

  • Structuring of international operations to reduce tax exposure

  • Use of Double Taxation Avoidance Agreements (DTAAs)

  • Tax-efficient repatriation strategies

• Global Structuring & Re-structuring

  • Incorporating tax-efficient holding or subsidiary companies

  • Mergers & acquisitions with tax optimization

  • Exit strategies including divestitures and repatriations

• Permanent Establishment (PE) Risk Management

  • Evaluating PE exposure under tax treaties

  • Structuring operations to mitigate PE risks

  • Documentation and reporting

• BEPS (Base Erosion and Profit Shifting) Advisory

  • Country-by-country (CbC) reporting

  • Risk assessments and policy design

  • Alignment with global anti-avoidance measures

• Tax Compliance & Reporting

  • Filing of international returns and disclosures

  • FATCA/CRS reporting

  • Assistance with audits and notices from tax authorities

Transfer Pricing Services

• Documentation:
  • Preparing comprehensive transfer pricing documentation to support the arm's-length nature of intercompany transactions. This documentation is essential for demonstrating compliance with tax authorities.
  • Assistance with local transfer pricing compliance documentation, Master File and country-by-country (CbC) reporting.
  • Transfer Pricing Study Reports

• Advisory:
  • Providing guidance on developing and implementing transfer pricing policies.
  • Analyzing and evaluating related-party transactions to ensure they adhere to arm's-length principles.
  • Assistance in setting up business/operational models, and restructuring existing business models to build tax/commercial efficiencies.

• Risk Assessment and Planning:
  • Identifying and mitigating transfer pricing risks.
  • Developing proactive transfer pricing strategies to optimize tax efficiency.

• Dispute Resolution:
  • Representing clients in transfer pricing audits and disputes with tax authorities.
  • Assistance with Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs).

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  Expatriate Tax Services

  Managing tax obligations for individuals living and working abroad.

  1. Tax Residency & Global Tax Compliance

  • Determining tax residency status under local laws and tax treaties

  • Filing personal income tax returns in home and host countries

  • Advising on split-year treatment and dual residency

  2. Income & Benefit Structuring

  • Optimizing salary structures, allowances, and benefits (e.g. housing, travel, relocation)

  • Tax treatment of stock options, bonuses, and deferred compensation

  • Double Taxation Avoidance Agreement (DTAA) planning

  3. Social Security and Retirement Contributions

  • Social security totalization agreements

  • Advice on host/home country pension schemes and exemptions

  4. Tax Equalization & Tax Protection

  • Designing and implementing tax equalization or protection policies for international assignees

  • Ensuring employees neither gain nor lose due to tax differences between countries

  5. Expatriate Payroll Management

  • Managing payroll across multiple countries

  • Withholding tax compliance and employer reporting obligations

  6. Exit and Repatriation Tax Planning

  • Planning for the end of an international assignment

  • Repatriation of income/assets and compliance with exit formalities

   

  Audit Support Services

  Assistance during international tax audits or inquiries

  1. Pre-Audit Risk Assessment

  • Review of international tax positions and transactions

  • Identification of potential red flags in filings or documentation

  • Stress-testing your structures (e.g. permanent establishment risk, treaty eligibility)

  2. Transfer Pricing Defense

  • Preparation or review of transfer pricing documentation (Local File, Master File, CbCR)

  • Economic analysis and benchmarking reports to justify arm’s-length pricing

  • Assistance in responding to transfer pricing audits and inquiries

  3. Tax Documentation Review

  • Verification of tax returns, declarations, and disclosures (e.g. Form 15CA/CB in India)

  • Review of foreign tax credits claimed

  • Support with FATCA/CRS reporting

  4. Support During Tax Authority Interactions

  • Representation before tax authorities during audits or investigations

  • Drafting and reviewing responses to notices or queries

  • Coordination with tax authorities  in appeal proceedings at , Assessing Officer level, Commissioner of Appeals, Income tax Appelate Tribunal

  5. Dispute Resolution & Litigation Support

  • Assistance in mutual agreement procedures (MAPs) under tax treaties

  • Advance Pricing Agreements (APAs) support

  • Legal drafting for appeals or representation in tax tribunals

  6. Post-Audit Compliance & Remediation

  • Rectification of errors or misstatements fo

    Double Taxation Avoidance Services

    1. DTAA Eligibility & Benefit Assessment

    • Determine if the taxpayer is eligible for treaty benefits

    • Choose between exemption method or tax credit method

    • Identify beneficial provisions (e.g. reduced withholding tax rates)

    2. Certificate of Residence (COR) & Form 10F

    • Assistance in obtaining COR from the tax authorities

    • Preparation of Form 10F (for Indian residents)

    • Compliance with treaty disclosure rules

    3. Tax Residency & Permanent Establishment (PE) Advisory

    • Identify if a PE is triggered in the source country

    • Structuring to avoid unintended PE exposure

    • Residency planning for tax efficiency

    4. Withholding Tax Relief

    • Advisory on lower TDS (withholding tax) rates under DTAA

    • Assistance in filing Form 15CA/CB (India) or equivalents globally

    • Application for lower/nil deduction certificates from tax departments

    5. Foreign Tax Credit (FTC) Advisory

    • Claiming FTCs in the country of residence for taxes paid abroad

    • Documentation support for FTC claims

    • Mitigating risks of disallowance due to documentation lapses

    6. MAP (Mutual Agreement Procedure) & APA Support

    • Filing for MAP to resolve double taxation issues between countries

    • Negotiating Advance Pricing Agreements for predictable outcomes

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