Businesses are ever evolving. Tax implications for different business models and different and are also continuously evolving.
The international tax scenario worldwide has been substantially transformed over the past few years with developments such as revised definitions of Permanent Establishments, tax aspects of digital economy, limitation on interest deductions, exchange of information, signing of multilateral instrument etc. MNEs are facing heightened risks of double taxation because of this constantly evolving environment. On the other hand, very conservative tax positions would increase the effective tax rate (ETR) for the MNE group.
While advising on today’s issues, it is imperative to also have a futuristic approach and based on the direction of the development of administrative and judicial view-points, also consider how the issue is likely to be viewed by the tax authorities and Courts after a few years.
Our corporate tax services to Indian and foreign businesses include:
Advisory services, including
- Transaction structuring and contract structuring
- Tax and operational analysis relating to Permanent Establishment (PE)
- EPC contract structuring
- Tax risk mitigation strategies
- Effective Tax Rate optimisation
- Withholding tax health-check and regularization, with corresponding tax credits
- Transaction tax advisory in business reorganisations such as M&A, demergers, take-overs, slump sales etc.
- Comprehensive advice relating to tax aspects of foreign companies in India
- Advice on specific provisions, such as those relating to equalisation levy, General Anti-Avoidance Regulations (GAAR), limitation on interest deductions etc.
Representation and litigation
- Procuring lower / Nil withholding tax certificates for various foreign payments
- Representing foreign shipping companies for Double Income Tax Relief Orders
- Tax representation for various cross-border tax matters
- Litigation support at various levels
Compliance services
- Advice on withholding taxes relating to foreign remittances
- Tax Return filing for foreign companies, including PE’s Tax Return in India
- Withholding tax return filing