International Tax Services

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  • International and cross border tax services

    • Advice on India tax and regulatory implications on cross-border/overseas transactions
    • Advice on Permanent Establishment exposure of foreign company in India and consequent tax implications
    • Advise on withholding tax implications in the hands of Indian company for various transactions with foreign company/non-resident person
    • Advice on applicability of Place of Effective Management (POEM) provisions for determining tax residential status of a foreign company/overseas entity in India and consequent India tax implications
    • Evaluating applicability of Indian Indirect transfer provisions on overseas transfer of shares of foreign company whereby shareholding of Indian company is indirectly transferred
    • Advising on taxability of capital gain on sale of shares of Indian Company by a foreign company/non-resident
    • Preparation and filing of foreign company income tax returns in India
    • Obtaining foreign company tax registrations in India
    • Review and drafting of agreement for cross border transaction undertaken with group company or with third party
    • Assisting foreign company in filing of form 10F electronically on India Income tax portal
    • Issuance of Chartered Accountant's certificate (Form 15CB) for foreign remittances

  • India entry (inbound) tax and regulatory services

    India offers attractive opportunities for Foreign Direct Investment (FDI). As on date major sectors are open for FDI under Automatic Route. We leverage our comprehensive understanding of Indian business environment, tax and regulatory structure to deal with complex cross border business issues. Our range of services includes:

    • Discussion and advise on availability of various central/state government incentives to your business
    • Holding company jurisdiction analysis for optimization of tax cost at the time of cash repatriation
    • Advising on FDI / Reserve Bank of India regulations as applicable to your business model
    • Advising on form of entity to be established viz. Private Company (in form of subsidiary or joint venture), Limited
    • Liability Partnership (LLP), Branch office, Liaison office or Project office and assistance in setting up/incorporation process
    • Advising on appropriate funding mix of Debt and Equity for tax cost optimization
    • Tax and regulatory due diligence of target company in case of business acquisitions
    • Obtaining necessary tax registrations for newly set up entity/office
    • Accounting and book-keeping services
    • CFO services
    • Ongoing tax compliance services such as filing of annual income tax return, corporate tax advisory, etc.

  • Corporate tax services

    • Obtaining tax registrations such as Permanent Account Number, Tax deduction account number, profession tax, etc.
    • Preparation and filing of annual income tax returns of corporate and LLP
    • Obtaining lower/NIL withholding (TDS) certificates/ order from tax authorities
    • Employee compensation structuring advisory
    • Review of ongoing tax litigations/ contingent liability statement and other tax positions, to comment on the probability of success for FIN 48/ statutory audit purposes
    • Advice on withholding tax implications arising from various transactions or arrangements proposed to be entered by the businesses
    • Corporate Tax/withholding tax compliance health checks
    • Conducting Income Tax compliance training and workshops for finance/tax teams
    • Employee stock option plans structuring and advisory
    • Representation (physical/ virtual) before tax authorities in regular tax assessments, tax re-assessment, etc.
    • Assistance in filing and representation for tax appeals before Commissioner of Income-tax (Appeals), Dispute Resolution Panel and Income tax appellate tribunal

  • Expatriate Taxation Services

    • Tax efficient structuring of secondment/deputation arrangement for inbound expatriates which shall include advisory on Permanent Establishment issues for foreign employer company, applicability of short stay exemption, applicability of India social security contributions, implications under foreign exchange regulations and other tax compliance requirements
    • Review of employment contracts of expatriates and secondment/deputation agreements from tax and regulatory perspective
    • Advising on taxability of remuneration of expatriates deputed/seconded to India including determining his residential status, availability of tax exemptions, tax credits, etc.
    • Advising on taxability of employer and employee contribution to retiral benefits of the home country during the term of deputation/secondment to India
    • Preparing monthly withholding tax computation for remuneration payable to inbound expatriates
    • Filing quarterly withholding tax returns for employer foreign/Indian companies and assistance in issuing Form 16 to Expats
    • Assistance in preparation and filing of India annual tax return of expatriate and employer foreign company

  • Transfer pricing services

    • Development and documentation of Transfer Pricing (TP) policy
    • Assistance in the preparation of contemporaneous documentation as required under the Indian TP regulations
    • Preparation of TP study report, Country By Country Report, Master File and Local File as required under Indian TP regulations
    • Benchmarking of international transactions for group companies
    • Transfer Pricing dispute resolution strategy formation
    • Advance Pricing Agreements
    • Advising on Safe Harbour rules applicability and carrying out requisite compliance
    • Issue of TP audit certificate in Form 3CEB
    • Assistance in TP litigation before various tax authorities

Our Subject Matter Expert:

CA Jhankhana Shah

Jhankhana is a subject matter expert and specializes in Tax Compliance Support and advisory (domestic tax and international tax) / Investment Structuring (Inbound as well as Outbound) / Representation for Tax Assessments/re-assessments and Appeals / Non-resident/ Expatriate taxation

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