Our Services
Overview
Tax and regulatory issues are complex and deeply intertwined with business operations. We offer a broad range of services in the areas of Direct Tax, Transfer Pricing, International Tax, Expatriate Tax, Indirect Taxes, and Regulatory affairs. Our philosophy is to listen to our clients and apply our vast knowledge and experience to provide solutions for their complex and strategic tax and regulatory issues. Our position as a premier tax advisor is built on the professionalism of our people, the quality of our services, and the trust we have earned from our clients. We contribute to the well-being of our clients by relieving them of the burdens associated with tax disputes.
Direct Tax
The Indian taxation system is widely regarded as one of the most complex in the world. Frequent amendments to income tax laws, along with regular notifications and clarifications issued by the Ministry of Finance, often create significant interpretational challenges for businesses. Effective tax planning and accurate advisory support are essential to reduce tax exposure and minimize the risk of litigation.
Our Direct Tax Services include:
- Corporate tax compliance
- Corporate tax planning and advisory services
- Withholding tax compliance and advisory
- Mergers and Acquisitions tax advisory, including due diligence and allied services
- Representation before the Central Board of Direct Taxes (CBDT) and the Ministry of Finance
- Assistance in drafting writ petitions before the High Courts and the Supreme Court
- Preparation of briefs for Senior Counsel in matters before the Supreme Court and High Courts
- Representation before the Income Tax Appellate Tribunal, including appeal drafting
- Representation before the Authority for Advance Rulings
- Representation before the Commissioner of Income Tax (Appeals) / Principal Commissioner of Income Tax
- Representation before Assessing Officers
- Follow-up with tax authorities for giving effect to appellate orders, rectification proceedings, and recovery of pending refunds
- Assistance in obtaining written legal opinions from Senior Counsel on complex tax issues
- Regular updates on notifications, circulars, orders, and clarifications issued by the CBDT
International Tax
Multinational enterprise groups operate across multiple jurisdictions to access global markets and optimize operational costs. This necessitates careful international tax planning to manage tax liabilities across jurisdictions while ensuring compliance with applicable laws and treaties.
We advise foreign investors exploring business opportunities in India and Indian companies engaging in cross-border transactions with overseas group entities and third parties.
Our International Tax Services include:
- Analysis of Permanent Establishment (PE) exposure and related planning
- International tax planning, including evaluation under General Anti-Avoidance Rules (GAAR)
- Advisory on taxability of branch offices, project offices, and liaison offices of foreign companies in India
- Review of royalty agreements and service contracts to determine taxability under Indian tax law and applicable DTAA read with MLI
- Advisory on withholding tax obligations for cross-border payments
- Advisory on investment holding and ownership structures
- Advisory on asset transfers between Indian and foreign entities
- Inbound business structuring
- Structuring of cross-border acquisitions
- Representation before assessment authorities and the Dispute Resolution Panel, including drafting of objections
- Representation before appellate authorities, including appeal drafting
- Assistance in Mutual Agreement Procedure (MAP) under tax treaties
- Assistance in obtaining written opinions from Senior Counsel on complex international tax matters
Transfer Pricing
Since the introduction of Indian Transfer Pricing Regulation via the Finance Act of 2001, this area has emerged as a critical challenge for multinational enterprises operating in India. The subsequent surge in litigation demands expert guidance from advisors who possess profound technical knowledge and strategic insight into the Indian tax landscape.
The Indian Transfer Pricing Regulation is broadly based on the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The Indian Transfer Pricing Regulation defines international transaction, prescribes various methods of determination of arm’s length price of international transaction, imposes extensive annual Transfer Pricing documentation requirements, and contains harsh penal provisions for non-compliance of relevant provisions of law.
The Finance Act, 2012, has expanded the scope of application of the Indian Transfer Pricing Regulation by incorporating therein specified domestic transactions. For implementing the OECD’s ‘Base Erosion and Profit Shifting’ (BEPS) Action Plan, 2013′, the Central Board of Direct Taxes has prescribed for maintenance and furnishing of ‘Master File’ and ‘Country-by-Country’ Report.
We offer full-range services in the area of Transfer Pricing which are stated below:
- Issuance of Accountant’s Report disclosing the international transactions and specified domestic transactions and methods applied in relation thereto
- Preparation of Transfer Pricing Study Report (undertaking domestic and foreign benchmarking, royalty benchmarking etc.) and assistance to the client in preparing master file and country-by-country report
- Preparation of brief for Senior Counsel in respect of Supreme Court and High Court matters
- Representation before the Income Tax Appellate Tribunal (including appeal drafting)
- Representation before the Commissioner of Income Tax (Appeals) (including appeal drafting)
- Representation before the Dispute Resolution Panel (including drafting of objections)
- Representation before the Transfer Pricing Officer
- Advance Pricing Agreement
- Transfer Pricing planning and policy determination
- Other advisory services
- Assistance to the client in obtaining advice / opinion in writing from Senior Counsel in relation to complex Transfer Pricing issues
- Informing clients regarding the relevant notification / circular / clarification issued by the CBDT.
Expatriate Tax
We provide comprehensive advisory services relating to tax and regulatory implications arising from the secondment of expatriates to India. Our services cover permanent establishment risks, tax-efficient salary structuring, foreign exchange regulations, social security obligations, and compliance matters.
Services Rendered to Employers:
- Entry briefing for expatriate employees
- Determination of income tax liability and withholding obligations
- Preparation and filing of quarterly withholding tax returns (Form 24Q)
- Issuance of Form 16 and Form 12BA
- Tax equalization computations and hypothetical tax workings
- Exit briefing for expatriate employees
- Representation in assessment and appellate proceedings relating to expatriate taxation
Services Rendered to Expatriate Employees:
- Assistance in obtaining Permanent Account Number (PAN)
- Assistance with registration before the Foreigners Regional Registration Office (FRRO)
- Computation of taxable income and filing of income tax returns in India
- Disclosure of overseas income, assets, and liabilities where legally required
- Assistance in obtaining income-tax clearance certificates and FRRO exit formalities prior to departure from India
Indirect Taxes
A. Goods & Services Tax (‘GST’)
We offer comprehensive services in the area of Goods & Services Tax which are stated hereinbelow.
- Preparation of monthly and annual returns
- Drafting reply to audit query and show cause notice
- Appeal before Commissioner (Appeals)
- Appeal before Goods and Service Tax Appellate Tribunal
- Giving opinion on various GST issues and preparation of brief for Senior Counsel in this regard
- Securing GST refund
- Informing the clients regarding relevant notification / circular / clarification issued by the CBIC
B. Erstwhile Service Tax
- Representation before Customs Excise & Service Tax Appellate Tribunal
- Preparation of brief for Senior Counsel for the High Court matters of clients
C. Other Indirect Taxes
- Compliance, litigation and advisory services in the area of Customs and Foreign Trade Policy
- Assistance to the client with respect to any special valuation branch proceedings
- Assistance to the client with respect to various incentive schemes such as Advance Authorisation, Export Promotion Capital Goods (EPCG) etc.
- Litigation support in respect of the pending issues in the area of the erstwhile indirect taxes
Regulatory
Foreign investors entering or operating in India must navigate a complex regulatory framework. We provide comprehensive regulatory advisory services to support such entities.
Our Regulatory Services include:
- Advisory on regulatory compliance for foreign investors
- Assistance in securing approvals from RBI, SEBI, and other regulatory authorities
- Advisory on Foreign Exchange Management Act (FEMA)
- Advisory on monetary, credit, and policy regulations of the Government of India
- Advisory on financial and risk management matters
- Assistance in obtaining expert opinions from Senior Counsel and former senior officials of RBI and SEBI
- Other regulatory advisory services