International taxation and transfer pricing
For multinational groups, foreign investors and non-residents: cross-border structuring, treaty positions, withholding, transfer pricing documentation and APAs.
What we do
Cross-border tax advisory
Analysis and structuring of tax implications for international transactions, including issuance of certificates in Form 146.
DTAA and MLI advisory
Guidance on treaty benefits, withholding taxes and Multilateral Instrument implications.
Tax residency and treaty documentation
Assistance with tax residency, treaty-related documentation and prescribed certifications in Form 146.
NRI taxation
Tax advisory and compliance for NRIs, foreign individuals and overseas entities.
Foreign investment and entry strategy
Tax and regulatory advisory for foreign investment, Indian incorporation and branch or liaison office structures.
Transfer pricing
Transfer pricing study reports, benchmarking, documentation and regulatory compliance, including prescribed reports, certifications and ongoing compliance under the Income-tax and Companies Acts.
Advance Pricing Agreements (APAs)
Advisory and end-to-end assistance for unilateral, bilateral and multilateral APAs.
Country-by-Country Reporting (CbCR)
Advisory and compliance support for multinational group reporting requirements.
Master File
Preparation and compliance support for Master File documentation.
International tax litigation and representation
Representation and strategic assistance in cross-border tax assessments, disputes and proceedings.
Relevant experience
Transfer pricing and international taxation. Transfer pricing study reports; TP assessments; Advance Pricing Agreements; international taxation and related certification and advisory assignments.
