Tax Services
Planning and Advisory
- Set up related advice relating to structuring of entity, capital mix and investment route
- Tax holiday claims, tax incentives and Govt. incentives
- Set up of international presence in global markets with strategic tax structuring, transfer pricing analysis, foreign tax compliance and substance requirement.
- Undertake comprehensive review of tax and TP positions of international businesses and provide suggestions for integrated tax optimisation (TP risk standpoint and BEPS Impact)
- Advice on cross-border withholding tax applicability and Permanent Establishment (inbound and outbound)
- Profit attribution analysis for Permanent Establishment
- Advice on appropriate TP model and provide benchmarking services
- Inter-company transfer pricing agreement
- Review of cost allocation keys in segmental accounts for transfer pricing
- Tax accounting issues
- Strategy for monitoring and managing Effective Tax Rate (ETR)
- Employee compensation structuring
- Structuring philanthropic initiatives
Compliances
- Obtaining tax registrations
- Undertaking periodic compliances and filings
- Low/Nil Withholding Tax Certificates
- Tax Reporting
- Transfer pricing documentation and certification
- Master File
- Country by Country reporting
- Post APA compliance and filings
Litigation and controversy management
- Strategy for resolution of pending litigation issues and unlocking refunds
- Representation before field officers, Commissioner Appeals, Dispute Resolution Panel, Income-tax appellate tribunal
- Advice on strategy for High Court and Supreme Court appeal and provide end to end support with representation
- Obtaining advance ruling
- Advice and assist with filing and representation under Safe harbour programme
Specialty services
- Transfer pricing business restructuring
- Advice on GAAR, BEPS and MLI
- ICDS advisory
- High level advisory on overseas/ foreign tax implication
- Preparation of global transfer pricing policy and operating manual for the Group
- Preparation of global TP benchmarks and TP documentation (OECD compliant)
- Valuation for related party transactions (Intangibles, business, contracts etc.)
- Provide report on arm’s length pricing or reasonable pricing for reporting to board or under other regulations
- Filing and negotiating Advance Pricing Agreement/ Mutual Agreement Procedure
- Support on Joint Venture pricing and negotiation
