• International Tax & Transfer Pricing

  • International Tax & Transfer Pricing

Business & Investment Structuring

With increased globalization and liberalized economic policies, India has become an attractive destination both from an inbound and outbound investment perspective. This necessitates business enterprises to expand and diversify, thereby raising complexities of tax related and regulatory framework. It becomes increasingly important for business enterprises to find new ways to align their tax strategies with their overall business needs and objectives, while also meeting compliance requirements as they arise. Therefore, in today's global economy, effective tax planning can offer a significant competitive advantage.


Cross Border Transaction Advisory

We assist client in structuring their cross-border transactions from tax and regulatory efficiency point of view. Our professionals assist clients through several critical issues such as, structuring foreign investments into India, designing capital and financial structures to optimize cross-border investment benefits while optimizing tax exposures and rendering advice on issues related to withholding taxes for cross-border payments. Our practitioners monitor and advise on the overall tax strategy of clients keeping in view the ever changing dynamics of tax law and tax policy across the globe.

Corporate Restructuring

With in-depth understanding of the domestic regulatory environment, commercial and tax considerations involved in the corporate restructuring exercise, our professionals help clients address vital business issues and provide effective solutions. We analyze and understand the clients’ business objectives that help us to design and offer customized solutions to clients including the appropriate tax and accounting treatment under corporate restructuring exercise. As part of ensuring implementation of the strategy in an efficient manner, we also extend our support in obtaining related regulatory approvals and permissions.

Acquisitions, Joint Ventures and divestments:

Our service includes acquisition tax planning, joint-venture tax planning, post-merger integration and disposition tax planning. We also provide negotiation assistance that include obtaining regulatory approvals from the Regulatory bodies, the Reserve Bank of India ('RBI') and relevant tax authorities.

Mergers and demergers:

We help clients address critical tax and regulatory issues that are involved in a merger and demerger process. We assist client to conceptualize mergers and demergers from tax & regulatory and undertake the regulatory valuation of the entities involved to determine the swap ratio for the merger /demerger. We work in close association with legal advisors for effective judicial proceedings and also assist client teams with essential documentation, whenever necessary.

NRI & Foreign National Advisory Services

We offer various consultancy and advisory services in connection with taxation matters as well as exchange control regulations to foreign nationals coming to India as well as Indians going abroad.

Inbound and Outbound Advisory Services

Our inbound advisory service is designed to assist overseas clients with some of the key tax issues, registration and other requirements of Indian laws. We help design the roadmap for entering the Indian marketplace to help with a smooth, timely, and compliant set-up. We also provide advisory services regarding outbound transactions in relation to taxation and other laws to our clients.

Transfer Pricing

With increase in cross-border activities combined with the introduction of transfer pricing legislation in India, transfer pricing has now assumed great importance in India.

Formulating appropriate transfer pricing policies for intra-group transactions, ensuring limited tax exposure and advising the client on compliance and regulatory issues, require in-depth knowledge of complex Indian tax laws, rulings, regulations and methods as well as a strong understanding of mandatory document requirements.

Our transfer pricing team comprises tax experts who play an integral role in various phases of a transfer-pricing planning. We work with clients in a collaborative manner for understanding the client's business so as to assist them in development of appropriate transfer pricing policies.

We draw on extensive experience in handling transfer pricing issues and extend our support to clients, including:

Transfer Pricing Planning & Advisory:

We assist clients with the study of their business operations, intra-group transactions and recommend long-term transfer pricing strategies including the methodologies to be adopted, by developing detailed reports on transfer pricing assignments.

Transfer Pricing Documentation

We assist clients with the study of their business operations, intra-group transactions and recommend long-term transfer pricing strategies including the methodologies to be adopted, by developing detailed reports on transfer pricing assignments.

Transfer Pricing Audit & Certification:

We assist clients with the study of their business operations, intra-group transactions and recommend long-term transfer pricing strategies including the methodologies to be adopted, by developing detailed reports on transfer pricing assignments.

Transfer Pricing Representations & Litigation

We represent clients at levels before tax authorities and appellate bodies. We assist clients and their legal counsel while representing their case before the courts on their transfer pricing litigation.

We assist clients in analyzing, preparing and representing cases suitable for entering into Advance Pricing Arrangements (‘APAs’) with tax authorities in respect of international transaction to which transfer pricing provisions apply.

Tax litigation Support Services

We help client administer their case from the early stages of litigation through appeals or alternative dispute resolution. Drawing on our tax litigation support experience gained in a large number of cases, we work closely with the law firms to identify relevant commercial, regulatory, tax and accounting issues at an early stage.