JMP Advisors
Tax Matters – NOVEMBER 2024
At JMP Advisors, we advise domestic and multinational clients on all aspects of taxation i.e. advisory, litigation and compliance. We provide services covering the entire gamut of taxation such as corporate tax, cross border tax, transfer pricing including APAs and MAPs, Goods and Services Tax (‘GST’), inbound and outbound investment, services to Foreign Portfolio Investors (‘FPI’), taxation of high net worth individuals including family arrangements and succession planning, etc. Our team brings together collective experience across service areas and industries to provide deep insights to our clients on various issues.
• 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)
• 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
• 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
• Assistance in representation before Indian Revenue authorities for assessments, stay proceedings and appeals, including in respect of transfer pricing issues
• Preparation, review, filing and arguing of appeals, applications to DRP and Authority for Advance Rulings (AAR)
• Advising on various business laws such as corporate law, law relating to Limited Liability Partnerships (LLPs), exchange control regulations, regulations governing banks and insurance companies, etc.
• Advising on various issues under the GST law and reviewing positions adopted by the clients to ensure conformity with the law
Our team’s rich and diverse experience of cross border deals combined with local knowledge enables us to expertly navigate through the labyrinth of Indian tax laws and regulations in order to provide bespoke solutions to our clients. We assist our clients in deal negotiations, undertaking buy side and sell side due diligence, including due diligence for distress sale of business and assets and identifying opportunities among companies undergoing corporate insolvency resolution process. We provide end-to-end assistance through the entire transaction life cycle and assist in implementation of the transaction as well, including working closely with investment bankers and lawyers, obtaining necessary approvals, post approval compliances and incorporating new legal entities as required.
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