International Taxation

• Consultancy on Withholding of Taxes
• Supporting to understand DTAAs
• Expatriate Taxation
• Analysis of deductions, exemptions etc. available
• Advising on DTAAs between India and other countries
• Liaison on Financing options for foreign entities
• Helping in location tax benefits for holding/subsidiary companies set up.
• Providing support in Departmental Litigation.
• Assisting on Departmental Representation.
• Watching supply chain that optimize in a manner to be tax efficient.
• Preparing and filing tax return, applying provisions of DTAA.
• Checking applicability of transfer pricing regulations.
• Assessing the requirement of documents.
• Analysis of transfer of goods or services.
• Pricing strategy analysis
• Calculation of profits
• Finding best applicable method
• Collecting Statistical facts
• Preparation of Transfer Pricing Study.
• Litigation support
• Planning and advising best transfer pricing strategy in order to have minimal risk

Transfer Pricing

• Transfer Pricing Documentation – We assist corporations to design and implement compliance policies, and prepare robust documentation.
• Transfer Pricing Planning & Supply Chain Structuring – We provide assistance in developing and implementing viable Transfer Pricing policies, harmonization of existing Transfer Pricing policies, adopting new Transfer Pricing structures or alignment of prices with business restructuring.
• Filing of audit report with the Indian tax authorities – we assist you with a full array of documentation services, including function, asset and risk analysis, industry overview, bench marking study, preparation and issuance of accountant’s report, customized to your specific needs.
• Litigation Support / Transfer Pricing Controversy Management – team will work with you to develop strategies and appropriate practices to manage the audit/appeal proceedings.
• FIN 48 Assistance – We provide assistance to determine and quantify your FIN 48 Transfer Pricing exposure and uncertain tax position.
• Advance Pricing Arrangements – We can assist preparing a robust Transfer Pricing policy aligning with business and commercial substance along with deciding on various documents and information that need to be shared with tax authorities during the course of negotiating and implementation of an APA program.

Cross Border Transaction Advisory

We have extensive experience in developing optimal tax structures for both inbound and outbound investments. The structuring of inbound and outbound investments starts with an understanding of the business expansion plans and objectives, and then a careful analysis of the applicable tax rules and rates for the home country and foreign jurisdictions.

Expatriate Tax advisory & Compliance

• Advisory Services on Secondment of Expatriate
  We provide a comprehensive analysis on the tax and regulatory implications on seconding an expatriate in India. The advice usually covers the Permanent Establishment issues, tax efficient salary structure advice, applicability of social security contributions, foreign exchange issues and other tax compliance requirements.
• Obtaining FRRO Registration (Foreign Regional Registration Offices)
  All foreigners visiting India on a long term visa of more than 180 days, are required to get FRRO registration done within 14 days of their arrival in India. Foreigners (including minors above the age of 16) need to get their registration done. Therefore, the family members of the expatriate, above the age of 16 will have to get themselves registered.
• Obtaining Permanent Account Number (PAN)
  We help obtain PAN, a unique identification number given by the Indian income tax authorities and an expat needs to obtain it in case his/her income is taxable in India. This is also used for filing a return of income in India.
• Computing Withholding taxes and making tax equalization statements
  – The entity employing the expats is required to withhold the taxes (accurately converting salaries in foreign currency as per the Income-tax Rules, 1962 and taking into account various exemptions and deductions) due on the salaries paid to those expatriates.
  – Post this withholding the entity needs to pay these taxes to the government and file quarterly returns of withholding taxes in Form 24Q with details of the expatriates.
  – At the end of the year, Form 16 which contains the taxes withheld and computation for taxable salary and Form 12BA containing detail of perquisites has to be issued.
  – We help in doing the tax equalization calculation and the hypo tax workings.
• Assistance in Income Tax Return Filing and disclosure of Foreign Assets and Liability
  We assist the expatriates in finalizing the computation for the relevant financial year and filing the income tax return before the due date i.e. 31st July of the next financial year. We also help the expat to disclose the overseas foreign assets and liabilities in case it’s applicable.
• Completion of Exit Formalities
  Prior to final departure from India, we can help the expat to obtain an Income-Tax Clearance Certificate (‘ITCC’) from the Indian tax authorities and get the FRRO cancelled. The ITCC is required to be presented to the immigration authorities.