International Services

International Tax Advisory

Cross-border transactions trigger issues related to permanent establishment, withholding taxes, profit attribution and treaty interpretation.

Our international tax advisory practice supports corporates and global investors in structuring transactions and managing cross-border tax exposure.

✔ Treaty Advisory & Structuring

• Interpretation and application of Double Taxation Avoidance Agreements (DTAA)
• Advisory on treaty benefits and anti-avoidance provisions

✔ Permanent Establishment (PE) Analysis

• Determination of PE exposure
• Attribution of profits to PE
• Advisory on mitigating unintended PE risks

✔ Cross-Border Transaction Advisory

• Advisory on royalty, FTS, ESOP taxation
• EPC and infrastructure contracts structuring
• POEM, BEPS and GAAR implications

✔ Withholding Tax & Remittance Advisory

• Lower/nil withholding certificate applications
• Tax certification for foreign remittances
• Compliance on repatriation of profits

✔ Litigation & Representation

• Representation before tax authorities
• Assistance in assessments and appeals
• Advance Rulings
• Mutual Agreement Procedure (MAP)

✔ NRI & Global Investor Advisory

• Tax planning for NRIs investing in India
• Capital gains advisory
• Repatriation and regulatory compliance

Our approach is analytical, treaty-aligned and risk-aware — ensuring that cross-border transactions remain commercially viable and legally defensible.