International Taxation Services

International Taxation Services

Our Direct Taxation team offers a comprehensive range of International Taxation Services, combining best practices with statutory compliance to help businesses optimize tax efficiency while managing risk.

With extensive experience in cross-border transactions, tax structuring, and strategic planning, our international tax advisors provide tailored solutions to complex tax matters. We help clients structure transactions, develop unique business models, and navigate evolving global tax regulations.

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Our International Taxation Services

Transfer Pricing & Compliance

  • International Transfer Pricing – Advisory on pricing policies for cross-border transactions in compliance with global regulations.
  • Country-by-Country Reporting (CbCR) & Master File Compliance – Assistance with documentation and compliance under OECD and Indian transfer pricing regulations.

Cross-Border Tax Planning & Structuring

  • Tax-Efficient Planning & Structuring – Optimization of cross-border transactions for tax efficiency.
  • Investment Restructuring – Strategic advice on reorganizing international investments.
  • Transnational Joint Ventures & Collaborations – Guidance on structuring joint ventures and business partnerships across jurisdictions.
  • Entry & Exit Strategies for India – Tax planning for foreign companies setting up or exiting business operations in India.
  • Formation of Association of Persons (AOPs) – Advisory on tax implications of AOP formation.
  • Taxation of Liaison, Branch & Project Offices – Structuring and tax compliance for foreign businesses operating in India.

Double Taxation & Treaty Advisory

  • DTAA Interpretation & Advisory – Expert guidance on Double Taxation Avoidance Agreements (DTAAs) and optimal utilization of tax treaties.
  • Permanent Establishment (PE) Analysis – Assessment and mitigation strategies for PE risks in India and abroad.
  • Withholding Tax Advisory – Assistance with withholding tax obligations, certifications, and compliance while conducting business with Indian clients.

Emerging Global Tax Regulations & Compliance

  • General Anti-Avoidance Rules (GAAR) – Advisory on tax avoidance regulations and risk mitigation.
  • Place of Effective Management (POEM) – Assessment of tax residency status for foreign entities.
  • Base Erosion & Profit Shifting (BEPS) – Compliance support for OECD’s BEPS action plan.
  • Multilateral Instruments (MLIs) – Guidance on tax treaties under the MLI framework.
  • Equalization Levy – Advisory on digital taxation and compliance for online businesses.

Taxation of Financial Transactions & Credits

  • Tax Aspects of Financing Transactions – Structuring loans, debt instruments, and hybrid financing arrangements.
  • Foreign Tax Credits (FTC) – Assistance with claiming tax credits and avoiding double taxation.

Litigation & Representation

  • Representation Before Tax Authorities – Assistance in tax disputes before the Income Tax Department, Dispute Resolution Panel (DRP), and Commissioner of Income Tax (Appeals) [CIT(A)].
  • Litigation Support – Representation before the Income Tax Appellate Tribunal (ITAT), High Courts, and Supreme Court.

NRI & Statutory Compliance Services

  • NRI Taxation & Advisory – Tax planning, compliance, and investment structuring for Non-Resident Indians (NRIs).
  • Statutory Compliance – Ensuring adherence to international tax laws and reporting obligations.