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International Tax Planning

Companies the world over are exploring options to expand in different geographies as globalization becomes absolutely essential. The opportunity to become global leaders is what is driving more and more companies out of their home countries.

Operating in multiple jurisdictions also brings opportunities to reduce costs and gain market share across countries. However, the complicated laws including the tax laws in different territories can make overseas expansion time consuming and costly. Whether you are an Indian company looking to expand overseas or a foreign company wanting to invest in India, you must understand the laws that can affect your business strategy and operations. We are members of reputed international alliances and have close relationships with our foreign affiliates who have the technical expertise to help you navigate through the complex maze of international tax laws worldwide.

International Tax Planning
A glance at the International Tax Services we offer to our clients:

International Tax Services for Foreign Investors exploring to do business in India

  • Setting up Fund and guidance on tax issues relating to the setting up and operation of the Fund
  • Inbound business structuring
  • Advice on taxability on Liaison Offices, Branch Offices and Project Offices
  • Advisory on Investment holding structures
  • International Mergers and Acquisitions (‘M&A’) tax and regulatory advice
  • Planning asset transfers between the Indian and foreign companies
  • Structuring for cross-border acquisitions
  • Permanent Establishment analysis including advise on the ways to avoid the exposure
  • Advice on Head Office charges and other PE tax issues
  • Analysis of Royalty and service contracts to determine the taxability by analyzing the Indian Income-tax Act, 1961 and the Double Taxation Avoidance Agreements
  • Withholding tax issues while doing business with Indian clients
  • Advice on how to avoid permanent establishment due to secondment of expatriates.
  • Tax issues relating to formation of Association of Persons (‘AOP’)
  • Customs issues on exporting to India
  • Indirect tax issues in Trading in India
  • Assistance in obtaining Special Valuation Bench Order for the Indian subsidiary for import from related parties
  • Advice on Inter Company charges and the direct tax and indirect tax impact on them
  • Guidance on equalization levy
  • Base Erosion and Profit Shifting (BEPS’) impact assessment and continuous guidance
  • Guidance on issues relating to TDS on Fee for Professional Services received from Non Resident, TDS on Royalty Payments, etc.
  • Help in Obtaining Tax Residency Certificates

International Tax Services for Indian Investors exploring to do business outside India

  • Outbound international business structuring
  • Strategizing structures for International Tax Planning and Management
  • Advise on setting up multi-tiered holding structures through tax efficient jurisdictions.
  • Structuring for cross-border acquisitions
  • Intellectual Property migration
  • Shifting the holding company outside India
  • Advice on utilization of foreign tax credits
  • Global Tax Planning and Management

Expatriate Taxation

With the huge influx of Foreign Direct Investment in India there has also been increase in demand of specialized skills of mobile employees known as ‘expatriate’ in India.

NRI Services

Companies the world over are exploring options to expand in different geographies as globalization becomes absolutely essential.

Transfer Pricing

Increased number of intercompany transactions has made transfer pricing a leading risk management issue for global businesses.