International Tax Services

Assisting with effective International Tax Planning Services

The globalization of the Indian economy has been taking place at a rapid pace, resulting in increased number of cross border transactions. Indian economy has shown great potential of growth and initiatives and has attracted foreign investors to invest in India. The increase in cross border transactions have a great impact on taxation of these transactions. The issues involved in the international taxation are complex in nature and requires professional support to deal in proper manner to comply with the same.

The traditional or conventional modes of doing business are shifting towards digital and modern mode globally. The tax jurisdictions worldwide are taking steps to strengthen the domestic tax laws and tax treaties to eliminate avoidance of taxes due to gaps in the existing tax structures. To minimize the incidence of double taxation there are various dispute resolution mechanisms available to the business entities.

To conduct business in tax efficient and compliant manner, the understanding and analysis of international taxation is important for any business entity. Under Direct Taxation vertical, we offer a wide range of International Tax Services. Our tax advisors who possess local expertise and global reach help with effective international tax planning services. Our International Tax Services are as follows:

1. Regulatory Approvals

• Analysing global entity structure and framing an optimal entry strategy for a foreign company in India
• Obtaining statutory tax registrations such as Permanent Account Number (PAN), Tax Deduction and Collection Number (TAN) for foreign companies/ their project office (PO), liaison office (LO) or branch office (BO) in India
• Obtaining Concessional Withholding Tax (WHT) Certificates for foreign companies

2. Statutory Compliances

• Tax compliances under international taxation for all international set-ups such as foreign companies / LO/ BO/PO including computation and payment of taxes considering impact of Income Computation & Disclosure Standards (ICDS)
• Assistance in filing of corporate tax and WHT returns for foreign companies
• Issuance of certificate required for purposes of making overseas remittance

3. International Tax Advisory Services

• Advisory on WHT implications on payments to non-residents and evaluation of tax treaties for availability of tax relief
• Advisory on Permanent Establishment (PE) exposure and corresponding tax impact
• Evaluation of claim of foreign tax credits and assistance in claim of tax refund from overseas authorities under international tax advisory services
• Advisory on availability/applicability of tax benefits under trade agreements

4. Emerging Areas

• Entity operational review to analyze the impact of Base Erosion and Profit Shifting (OECD BEPS)
• Analyze the impact of General Anti-Avoidance Rules (GAAR) on domestic and cross-border restructuring activities
• Analyzing impact of Place of Effective Management (POEM)
• Applicability of gains arising out of indirect asset transfers in India
• Tackling treaty abuse and treaty shopping

5. Representation Services

• Handling scrutiny assessments & representation before tax authorities for foreign companies
• Exploring alternative tax dispute resolution avenues for e.g.: Commissioner of Income Tax – Appeals (CIT-A), Dispute Resolution Panel (DRP) etc
• Litigation support before Indian Courts of Law through in-house and external expert legal counsels
• Preparing advance ruling application and representing before Authority for Advance Rulings (AAR) for settling a tax position involving non-resident(s)
• Drafting/Representing applications to the competent authority for Mutual Agreement Procedure (MAP) under tax treaties

To know more about other Direct Taxation Services, browse the below section-