• Advice on interpretation of Double Tax Avoidance Agreements (DTAAs)
• Identify potential double taxation and related issues and recommend alternatives to mitigate them taking into consideration the General Anti- Avoidance Rule (GAAR) including advice on Permanent Establishment and Place of Effective Management (POEM) issues, taxation of Digital Economy and impact of OECD in Base Erosion and Profit Shifting (BEPS) Actions on business activities, including the implications of the Multilateral Instrument (MLI)
• Advice on withholding tax matters and assistance in obtaining withholding tax orders
• Advice on tax efficient structuring of cross border transactions, including Holding company jurisdictions to encompass the entire gamut of inbound and outbound tax issues
• Advising Foreign Portfolio Investors (FPIs) on the process of registration, choice of jurisdiction, relief under the DTAA keeping in mind GAAR, analysing the applicability of indirect transfer provisions and assistance in maintaining the investment account in India, including computation of tax on capital gains