Tax and Regulatory Services

INTERNATIONAL TAX

• 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

INDIAN DOMESTIC TAX

• Advisory services relating to Indian Income tax law

• Tax planning strategies to mitigate the incidence of Indian tax

• Identify tax risks and exposures and recommend strategies to manage them

• Review contracts and recommend tax effective solutions

• Review tax impact of specific issues and amendments in tax laws and provide
tax opinions

• Advice on withholding tax obligations, assist in obtaining withholding tax orders, no objection certificates and tax registrations

• Preparation and filing of Indian corporate tax and other returns including advising on the Indian Accounting Standards (Ind AS) and Income Computation and Disclosure Standards (ICDS); advice on tax positions to be adopted in the returns

• Assistance in tax controversy management by providing litigation support at all appellate levels including alternate dispute resolution mechanisms

TRANSFER PRICING

• Undertake transfer pricing studies and suggest documentation required

• Recommend appropriate transfer pricing strategies

• Review of specified domestic transactions

• Assistance in issuing the Accountant’s Report in Form 3CEB as required under the Indian domestic tax law

• Advice on strategies to minimize transfer pricing adjustments

• Preparation of Mutual Agreement Procedure (MAP) applications and their representation

• Advisory and representation services for Advance Pricing Agreements (APA)

• Services relating to resolution of transfer pricing adjustments, including assistance in representation before Dispute Resolution Panel (DRP) and Appellate authorities

• Assistance on issues arising out of BEPS Actions and their recommendations

TAX DISPUTE RESOLUTION

• Assistance in representation before Indian Revenue authorities for assessments and, stay proceedings and Appellate authorities and Courts for appeals, including in respect of transfer pricing issues

• Preparation, review, filing and arguing of appeals, applications to DRP and Authority for Advance Rulings (AAR)

• Assistance in representation in respect of AAR, APA and MAP matters

BUSINESS LAWS AND REGULATIONS

• Advising on various business laws such as corporate law, law relating to Limited Liability Partnerships (LLPs), exchange control law and regulations, regulations governing banks and insurance companies, etc.

GOODS AND SERVICES TAX (GST) ADVISORY SERVICES

• Advising on various issues under the GST law and reviewing positions adopted by the clients to ensure conformity with the law

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