Nowadays, tax and regulatory issues are more complex and intertwined with business issues than before. We offer a broad range of services in the areas of Direct Tax, Transfer Pricing, International Tax, Expatriate Tax, Indirect Taxes and Regulatory. Ourphilosophy is to listen to the clients and to apply our vast knowledge and experience to provide solution for the complex and strategic tax and regulatory issues of the clients.

Our position as a tax advisor is based on the professionalism of our people, the quality of our services, the trust we have gained from our clients and the contribution we have made towards well-being of our clients by relieving them from worries relating to tax disputes.

Our clients are spread across industries including but not limited to:

• Automotive
• Aviation
• Banking
• Construction and materials
• Consumer goods and services
• Energy
• Financial services (including ‘Foreign Institutional Investors’, ‘Foreign Portfolio Investors’ etc.)
• Food and beverage
• Gaming
• Healthcare
• Industrials
• Media
• Mining
• Oil and gas
• Pharma and life sciences
• Real estate
• Shipping
• Tech and telecoms
• Transport
• Utilities

Indian taxation system is perceived to be one of the most complex taxation systems globally. The Ministry of Finance has been amending the income tax law frequently and issuing notifications and clarifications on regular basis. This causes inconvenience to the business houses in terms of interpretation of the provisions of income tax law.This makes handling of tax issues of the business houses very challenging. Suitabletax planning and correct tax advice are required to reduce the tax incidence and to minimise the risk of litigation significantly.

In the area of Direct Tax, we offer full range of services which are stated below:

• Corporate tax compliance
• Corporate tax planning and advisory services
• Withholding tax compliance
• Withholding tax advisory services
• Merger & Acquisition tax (including due diligence and allied services)
• Representation before the Central Board of Direct Taxes (CBDT) / Ministry of Finance
• Assistance in drafting ‘Writ Petition’ to be filed with High Court and Supreme Court
• Preparation of brief for Senior Counsel in respect of Supreme Court and High Court matters
• Representation before the Income Tax Appellate Tribunal (including appeal drafting)
• Representation before the Authority of Advance Ruling
• Representation before the Commissioner of Income Tax (Appeals) (including appeal drafting)
• Representation before the Assessing Officers
  Following up with the Assessing Officer for granting effect to the orders passed by the appellate authorities and the rectification petitions pending before him, which may enable the clients to get refund fromthe income tax department which may be due for considerable period of time and which may be of substantial amount
• Assistance to the client in obtaining advice / opinion in writing from Senior Counsel in relation to complex income tax issues
• Informing the clients regarding the relevant notification / circular / order/ clarification issued by the CBDT

The multinational enterprise groups operate in multiple tax jurisdictions in order to get access to the global market for their products and services and to economise on cost of operation. They are required to undertake tax planning so as to minimise the liability to pay tax in multiple tax jurisdictions. In this connection, they have to take advice from international tax experts who have comprehensive knowledge of the Double Tax Avoidance Agreements (‘DTAA’) / Multilateral Instruments (‘MLI’) and General Anti-avoidance Rules (GAAR).

In the area of International Tax, we offer the following services to the foreign investors exploring business opportunities in India and the Indian companies entering into various transactions with their overseas group companies and third parties abroad.

• Analysis of ‘Permanent Establishment’(‘PE’) issues and planning to avoid PE exposure
• International tax planning after duly considering the provisions of GAAR
• Advice on taxability of branch office, project office and liaisoning office of foreign company in India
• Analysis of royalty agreements and service contracts in order to determine the taxability in India after duly considering the provisions of the Indian Income Tax and the DTAA read with MLI
• Advice on withholding tax issues in respect of payments to be made by Indian company to foreign company
• Advisory on investment holding structure
• Advisory on asset transfer between an Indian company and a foreign company
• Inbound business structuring
• Structuring for cross-border acquisitions
• Representation of foreign client before the assessment authorities including Dispute Resolution Panel (including drafting of objections) and also before the appellate authorities (including appeal drafting)
• Mutual Agreement Procedure under tax treaties
• Assistance to the client in obtaining advice / opinion in writing from Senior Counsel in relation to complex international tax issues

Since the introduction of a separate code on transfer pricing in India by the Finance Act, 2001, transfer pricing has become an important tax issue that significantly affects the multinational enterprises operating in India. In recent years, the litigations in the area of transfer pricing has increased remarkably which require handling of the transfer pricing issues of the Indian companies by an advisor who has profound knowledge of transfer pricing.

The Indian transfer pricing regulation is broadly based on the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises and Tax Administrations. The Indian Transfer Pricing Regulationprescribes various transfer pricing methods of determining arm’s length price of international transaction, impose extensive annual transfer pricing documentation requirements, and contain harsh penal provisions for non-compliance of relevant provisions of law. The Finance Act, 2012, has expanded the scope of application of the Indian transfer pricing regulation by incorporating therein specified domestic transactions. For implementing the OECD’s ‘Base Erosion and Profit Shifting’ (BEPS) Action Plan, 2013’, the Central Board of Direct Taxes has prescribed for maintenance and furnishing of ‘Master File’ and ‘Country-by-Country’ Report by Indian assessees.

We offer full-range services in the area of transfer pricing which are stated below:

• Issuance of Accountant’s Report disclosing the international transactions and specified domestic transactions and methods applied in relation thereto
• Preparation of local transfer pricing study report and assistance to the client in preparing master file and country-by-country report
• Preparation of brief for Senior Counsel in respect of Supreme Court and High Court matters
• Representation before the Income Tax Appellate Tribunal (including appeal drafting)
• Representation before the Commissioner of Income Tax (Appeals) (including appeal drafting)
• Representation before the Dispute Resolution Panel (including drafting of objections)
• Representation before the Transfer Pricing Officer
• Advance Pricing Agreement
• Transfer pricing planning and policy determination
• Other advisory services
• Assistance to the client in obtainingadvice / opinion in writing from Senior Counsel in relation to complex transfer pricing issues
• Informing the clients regarding the relevant notification / circular / order/ clarification issued by the CBDT

We provide a comprehensive analysis of the tax and regulatory implications in respect of secondment of an expatriate in India. We advise our clients in respect of permanent establishment issues, tax-efficient salary structure of expatriate employees, foreign exchange issues, social security contributions and other tax compliance related issues. The services rendered by us in the area of expatriate taxation fall into two categories viz., the services rendered to expatriate employee and the services rendered to Indian employer.

Services rendered to employer:

• Entry briefing of expatriate employee to get the requisite information regarding taxation matters
• Assistance to the employer in accurately determining the income tax payable by expatriate employee in India and to withhold tax out of the salary of the expatriate employee at appropriate rate
• Assistance to the employer in the preparation and filing of withholding tax return in Form No. 24Q on quarterly basis
• Assistance to the employer in issuing Form No. 16 which contains the computation of salary of expatriate employee chargeable to tax in India and the details of income taxes withheld by the employer
• Assistance to the employer in issuing Form No. 12BA containing details of perquisites, profit in lieu of salary and other amenities given to expatriate employee
• Assistance to the employer in performing tax equalisation computation and working of hypothetical tax
• Exit briefing of expatriate employee to get the requisite information regarding taxation matters
• Assistance to the employer in handling the assessment and appellate proceedings in respect of the tax matters of the expatriate employee

Services rendered to expatriate employee:

• Assistance to the expatriate employee in obtaining permanent account number (PAN) in India which is required for filing return of income in India
• Assistance to the expatriate employee in obtaining registration with Foreigners Regional Registration Officer (FRRO) within14 days of his arrival in India
• Assistance to the expatriate employee in computing the taxable income and filing income tax return in India on or before the due date.
• Assistance to the expatriate employee in disclosing overseas income / asset / liability in the return of income filed in India in the event there is any legal requirement
• Assistance to the expatriate employee in securing refund of the employer’s contribution, employee’s contribution and interest thereon from the Provident Fund Authority after the expiry of service agreement in India
• Assistance to the expatriate employee, prior to final departure from India, in securing income-tax clearance certificate from the Indian tax authorities (which is required to be presented to the immigration authorities) and in getting the FRRO cancelled

A.Goods & Services Tax (‘GST’)

We offer comprehensive services in the area of Goods & Services Tax which are stated hereinbelow.

• Assistance to the client in loading data for the purpose of preparation of GST Returns in appropriate format and in running data validation process in electronic database which leads to generation of exception reports
• Assistance to the client in computing GST payable and the input tax credit (‘ITC’) eligibility
• Assistance to the client in the preparation of annual and monthly GST returns
• Assistance to the client in carrying out reconciliation between GSTR-3B with GSTR-2A/ GSTR-2B and between GSTR-3B with GSTR-1
• Assistance to the client in drafting reply to the routine query raised by the GST Officers from time to time
• Representation before the tax assessment authorities and the appellate authorities (including drafting of appeal)
• Assistance to the client in the matter of GST audit
• Assistance in drafting ‘Writ Petition’ to be filed with High Court and Supreme Court
• Assistance to the client in obtaining advice / opinion in writing from the Senior Counsel in relation to issues arising from the GST legislation
• Representation before the GST Council and the Central Board of Indirect Taxes & Customs (CBIC) for securing clarification on complex issues arising from the GST legislation
• Indirect tax health check in order to identify the areas of non-compliance, areas of possible tax exposure and areas of possible saving
• Informing the clients regarding the relevant GST notification / circular / order / clarification issued by the GST Council and the CBIC
• Assistance to the client in obtaining refund with respect to the input tax credit (ITC) on export done without payment of the GST, refund of the IGST paid on export done with payment of tax, inverted duty structure refund, TDS refund etc.

B.Other Indirect Taxes

• Compliance, litigation and advisory services in the area of Customs and Foreign Trade Policy
• Assistance to the client with respect to any special valuation branch proceedings
• Assistance to the client with respect to various incentive schemes such as Advance Authorisation, Export Promotion Capital Goods (EPCG) etc.
• Litigation support in respect of the pending issues in the area of the erstwhile indirect taxes such as Excise Duty, Service Tax and VAT

The foreign investors including companies looking to enter into India or already operating in India need to understand the Indian legal and regulatory environment.We offer comprehensive services in the area of regulatory which are stated below.

• Advisory services in the matter of compliance to be undertaken by the foreign investors in the present regulatory environment of India
• Securing necessary approvals fromthe RBI, the SEBI and other regulatory bodies
• Advisory services in relation to the Foreign Exchange Management Act
• Advisory services in relation to the monetary and credit policies of the Government of India
• Advisory services in relation to the financial management and risk management
• Assistance to the client in obtaining advice / opinion in writing from Senior Counsel and the retired Member / Director of the RBI and the SEBI in relation to complex regulatory issues
• Other advisoryservices