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    Helping our clients attain their business objectives within the regulatory ambit

    The ever-evolving tax landscape has had a profound impact on all industries and has forced the companies to view taxation from a strategic standpoint rather than a compliance requirement. Therefore, taxes have become an important element in shaping up of business strategies and hence, upfront advice can help in attaining tax efficiency. Our professionals are guided by a single, strong underlying philosophy 鈥� 鈥榟elping our clients attain their business objectives within the regulatory ambit 鈥�. We endeavour to adopt a 鈥榟andholding approach鈥� which encompasses various aspects of tax advisory.

    Our key service offerings include

    Domestic tax

    • Tax advice on various domestic transactions
    • Tax positions to be adopted in the return of income
    • Tax advisory in relation to agreements/arrangements between parties
    • Withholding tax implications on payments to residents/non-residents
    • Carrying out diagnostic health-check analysis from tax perspective.
    Domestic tax

    International tax

    International tax
    • Advice on various international tax matters involving cross-border transactions
    • Taxability of income of non-residents in India
    • Implications of transactions from Permanent Establishment (PE) perspective
    • Review of operations and analysis of impact qua Base Erosion and Profit Shifting (BEPS) measures, such as impact of multilateral instruments (MLI), Pillar 2, equalisation levy, significant economic presence (SEP) provisions, etc.
    • Eligibility to claim foreign tax credits.

    Anti-abuse provisions

    • Analysis of impact of General Anti Avoidance Rules (GAAR) on domestic and cross-border transactions/structuring
    • Implications under Place of Effective Management (POEM) rules for determining tax residential status of a foreign company/overseas group entity in India having regard to global management structure
    • Substance/beneficial ownership test analysis from tax perspective
    Anti-abuse provisions

    Advisory on tax controversies

    Advisory on tax controversies
    • Advising on uncertain/disputed tax positions, including in the context of recent developments from a tax controversy standpoint. For e.g., - refund of dividend distribution tax basis treaty rate, interpretation of MFN clause, software taxability qua specific facts, validity of reassessments, tax implications on secondment arrangements etc.

    Tax advisory in the context of India entry strategy

    • Tax advice on India entry approach and suggestions for obtaining optimal entity structure (such as branch, subsidiary, LLP, Joint venture)/holding company jurisdiction for investment in India
    • Assistance from a tax perspective in review of shareholders鈥�/joint venture/any other relevant business agreements
    • Tax advice in the context of repatriation strategies
    Tax advisory in the context of India entry strategy

    Outbound investment advisory

    Outbound investment advisory
    • Tax advice on cross-border investment strategies and suggestions for obtaining optimal ownership/jurisdiction structures for investment into a particular jurisdiction which includes setting up an international holding company, global sales company, etc.
    • Tax advice and assistance on entity structuring and capital structuring in the selected jurisdiction
    • Assistance from a tax perspective in review of shareholders鈥�/joint venture/any other relevant business agreements

    Key Contact

    Gaurav Mehndiratta

    Partner and National Head, Corporate and International Tax

    乐鱼(Leyu)体育官网 in India

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