Corporate tax

We will help our clients in:

Building sustainable tax strategies based on technical, practical, commercial and industry knowledge

Assessing, improve and monitor the tax function's processes, controls and risk management

Managing relationships with tax authorities effectively

We provide our clients with a complete gamut of tax advisory services ranging from tax planning to advice

Tax Advisory

Identifying various tax exposures and planning in efficient manner

Analysis of appropriate form of business vehicle to set up Indian business activities

Use of corporate tax incentives in the proposed business activities

Tax-planning strategies for profit and dividend repatriation

Alignment of tax with business strategies

Help resolve uncertain tax positions

Advising on withholding tax obligations on payment to resident and non residents

Assisting during tax audit by revenue authorities

Tax Compliance

Documentation, preparation and review of tax returns

Assistance in preparation and filing of withholding tax returns

Assistance in certification for cross border payments

Litigation

Drafting factual and legal submissions for income tax appeal before the appellate authorities

Effectively complying with appellate requirements and procedures

Preparing the case and representing it before the appellate authorities

Exploring and using alternative tax dispute resolution avenues

Preparing advance ruling application and representing before the Authority for Advance Rulings (AAR) for settling a tax position involving non-resident

Drafting and presenting applications to the competent authority for MAP under tax treaties (DTAA)

Reviewing pending litigation and other uncertain tax positions, to comment on adequacy of defence, probability of success and prevention of recurrence

In-house service of the expert counsel with experience in representation before appellate authorities including tax tribunal

Assisting the legal counsel in preparing or representing for appeals, writ petition and special leave petition before Indian Apex court (Supreme Court) and court subordinate to it (High Court)

Cross Border tax

Inbound tax advisory

Tax efficient holding company structuring;

Analysis of jurisdiction which would meet the tax and commercial objectives;

Determining appropriate capital structure which would address issues like ease of funding and tax optimization;

Analysis of Business models that restructure permanent establishment risks;

Evaluating IP domicile jurisdiction and structuring IP transfer in a tax efficient manner;

Tax efficient cash repatriation and upstreaming;

Outbound tax advisory

Selection of jurisdiction which would best meet the tax and commercial objectives;

Ascertain the applicability and mitigation of withholding taxes on cross border payments e.g., interest, royalties, dividends or branch payments);

Evaluate foreign tax credits, allocation of expenses principles, permanent establishments risks, etc;

Collaborate in the efforts for development, ownership and use of intangible property.

Transfer Pricing

Develop transfer pricing documentation

Develop better understanding of your transfer pricing risks, and implement consistent and defensible practices when controversies do arise

Develop strategies and guide you through the process of requesting APAs to help ensure successful outcomes

Governance optimization and decision making process to help:

Transaction tax

We provide end-to-end solutions for different types of domestic and cross-border transactions including mergers, demergers, acquisitions, divestitures, joint ventures, corporate restructuring. The services consider legislations and regulations such as direct tax, indirect tax, stamp duty, corporate laws, exchange control regulations, accounting standards, etc.

Human Capital

We help companies address:

Expats tax filing requirements at Home and host country

Permanent establishment risks, if any created by international assignees

Computation of Withholding tax to be deducted on expats income

Tax-efficient employment structures

Immigration and Visa related services

Social security compliance

Reviewing tax filing positions, equalisation policies, payroll reporting and withholding practices, handling of equity-based compensation, and inter-company charges relating to expatriate compensation to identify opportunities to reduce costs and manage risks.

We have extensive experience resolving issues related to:

Short-term assignees,

Tax treaty issues and eligibility,

Transfer pricing for cross-border labor,

Foreign tax credits, taxability of foreign-earned income and housing exclusions, and

Corporate PE Risk

Indirect tax

Structuring of contracts and transactions to optimise indirect tax incidence

Reviewing contract documentation

Formulating indirect tax efficient business models

Advising on classification, valuation, applicability of taxes on transactions and admissibility to tax benefits and exemptions

Giving opinions on other indirect tax issues

Undertaking comprehensive reviews of business operations to identify tax planning opportunities and compliance gaps

Conducting detailed indirect tax due diligence reviews

Providing advisory and operational assistance for benefits under free trade and regional trade agreements

Obtaining required registrations and licences

Helping avail of benefits under EXIM policy schemes

Setting up and operationalising EOUs, STP units or SEZ units

Giving indirect tax compliance support

Providing complete support for customs SVB proceedings

Drafting appeals, submissions and replies to notices

Companies Act

We can advise and assist in:

Structuring advise for transactions/ investments/ business models transactions in view of Indian regulatory framework;

Advise on regulatory environment impacting client's business, Mapping of regulatory processes; review/ drafting of documentation from regulatory standpoint

Representations before Government authorities and assistance in obtaining regulatory approvals/ clarifications/ dispensations from various regulatory authorities (including FIPB/ DIPP/RBI/ SEZs/ SEBI/ Central Govt. administrative ministries)

Regulatory Compliance/ Health Check Review, assistance in compounding & similar proceedings with various regulators

Advise on upcoming/ probable regulations, investment rules, licensing regime, investment scheme etc, dealing with ambiguity in current/ new regulations

Advising on regulatory implications of a particular transaction, business model etc, undertaking specific or turnkey ongoing regulatory compliances

Secretarial support and outsourcing