• 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
• Structuring for cross-border acquisitions
• Permanent Establishment analysis (due to Indian business operations and secondment of expatriates) including analysis on the ways to minimize double taxation tax exposure
• Analysis of Royalty and service contracts to determine their taxability in light of Indian Income Tax laws and the Double Taxation Avoidance Agreements.
• Withholding tax issues while doing business with Indian clients
• Indirect tax issues relating to trading in India
• 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.

• 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
• Advice on utilization of foreign tax credits
• Global Tax Planning and Management

With increase in increased globalization India is attracting many multinational enterprises (MNE) leading to extensive cross border transactions. It is also a fact that various entities in the MNE group structure have given rise to transfer pricing and issues related to such transfer pricing.

Consequently tax payers are required to comply with increased Transfer pricing documentation compliances and aggressive tax litigation in Indian Transfer pricing arena, which requires timely and robust transfer pricing policies and documentation. The global transfer pricing policy ensures consistent transfer pricing treatment of various global transactions as per standard transfer pricing methodology thereby mitigating the risk of economic double taxation.

Transfer pricing is generally considered an international tax issue. However in order to bring more scientific basis in determining fair market value in related party or specified domestic transactions, Domestic transfer pricing regime has also been introduced in India. These domestic transfer pricing regulations have introduced the concept of arm's length pricing for such specified domestic transactions.

We provide life cycle support for transfer pricing process, starting from transfer pricing study including documentation, certification, assessment to litigation. We also provide advisory on transfer pricing policies and structuring services keeping in mind the widely litigated issues in India such as Intangibles and share valuations, advisory for Safe Harbour regulations, assistance in entering into Advance Pricing Agreements (APAs) and support in Mutual Agreement Procedures (MAP).

• Transfer Pricing Audit
• Review and advice on Transfer Pricing Study Reports and Methodology