INTERNATIONAL TAX

As a global player, India too has a large Tax Treaty network having entered into Double Taxation Avoidance Agreement (‘DTAA / Tax Treaty’) with almost all the relevant Countries with dominant global trade. The international tax environment is becoming increasingly challenging and dynamic with the changing domestic laws, OECD’s action plan on Base Erosion and Profit Shifting (‘BEPS’), General Anti-Avoidance Rule (‘GAAR’) and its implications and the upcoming signing of Multi-lateral Instruments (‘MLI’). MLI will change the entire Tax Treaty dynamics and impact of the same needs to be clearly understood and strategically adopted. We can help businesses to achieve global tax efficiency by studying and analysing current structures as well as operational transactions and determining the most efficient way ahead.

ADVISORY

  • Applicability and interpretation of Tax Treaty
  • Advisory for restructuring of entities / operations with special emphasis on local tax laws as well as DTAA
  • Analysing tax residency under place of effective management (‘POEM’) rules (inclusive of MLI) having regard to global management structure; covering related impact as well as compliance requirements
  • Advice on Permanent Establishment (‘PE’) and its tax impact
  • Health check of business structures under GAAR
  • Health check of international structures as well as cross border operations through the lens of the internationally accepted MLI
  • Advisory on availing foreign tax credits in India or in overseas jurisdictions; including analysis of global structures from:
      • An ‘effective tax rate’ perspective; and
      • An ‘effective tax credit availability’

COMPLIANCE

  • Assisting foreign entities on compliance requirements
  • Assisting foreign entities during tax proceedings, including representation before various authorities