Our research team co-ordinates with the associates and implements the structures. Our good relations with our associates facilitates this and ensures that the anticipated benefits and values are realized and has the positive impact on the bottom line of the company as envisaged.

Our international tax specialists are trained to advise on various issues such as:

• Application of tax treaty interpretations not only in India but also in other jurisdictions
• Interpretation and advice on Most Favored Nation (MFN) clauses
• Anti-deferral regimes such as CFC, PFIC, etc
• Indirect taxes such as customs and VAT
• Entity selection and financial structuring
• Study of tax and regulatory mechanism in country of operation
• Identifying suitable holding company location
• Expatriate compensation structuring
• Obtaining withholding tax certificates and advance rulings in India and overseas
• Exchange control regulations and corporate compliances
• Acquisitions and business re-organisations including conversion of branch into subsidiary and vice versa

• Planning employee secondments v/s transfers
• Profit attribution in overseas branches
• Billing methodology
• Section 10A, 10B compliances and interpretation and interplay of STP regulations
• Minimization of withholding taxes
• Client contract monitoring on real time basis to ensure advance planning for any permanent establishment issues that may arise and enable effective pricing.

• Advising a large US private equity firm on consolidating the existing 8 investment structures with regard to US and Indian IT investments into a single holding company with a view to attracting capital from other institutional investors
• Advised a UK pharmaceutical company regarding tax minimization in UK and other jurisdictions on international royalty income from 5 countries
• Evolving an international structure for an ITES operation in India and marketing in US/ Canada and implementing the structure
• Advised an overseas dredging company on their dredging contract in India with a view to reduce overall Indian tax considering Indian and international tax structuring via an intermediate sub-contracting entity
• To evolve various different options in partnering with a Russian company to undertake EPC contracts in India considering tax minimization in India and Russia
• Advising one of the largest call centers in UK on regulatory permissions required in establishing an operation in India and the international tax planning associated with the decision to invest in India via a joint venture
• International tax planning/ structuring issues related to the establishment of a Greenfield packaging plant in India for a Canadian investor
• International tax planning issues related to the acquisition by an Italian company of a textile plant in India and in particular the payment of consideration to Indian seller
• Advising and obtaining tax refunds for a leading Austrian engineering company undertaking a turnkey contract for technical assistance and supervision to help an Indian company construct a magnesium sinter plant
• Providing an international structure for establishing operations in over 35 countries including China, Belgium, US, UK, etc for a leading healthcare company
• Advising a non-resident Indian on international tax issues relating to an airline start-up in India
• Providing a plan for merging the software operations in India with that of a UK associate software company
• Minimization of Indian withholding tax relating to fees being paid by a leading Indian investment bank to a large international consulting company which had offices in 5 cities abroad
• Tax planning and obtaining withholding tax certificate for an Israel based NASDAQ listed telecom software company.