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Tax and regulatory services

Direct tax and regulatory services

We offer a bouquet of fully integrated tax and regulatory services. Our extensive experience and in-depth knowledge combined with our insight and innovation helps dynamic businesses in their global operations.

With the increasing ease of doing business in India, investors are highly optimistic about making investments in the country. Our team of specialists assists businesses on various tax and regulatory matters at every stage of the business lifecycle, thereby enabling them to explore and make the most out of the opportunities.

We also advise clients on how to effectively navigate the myriad of tax, and regulatory issues in cross-border transactions to help manage compliance risks and potentially enhance returns.

Our specialist teams provide a holistic and the most tax-effective solutions to large multinational companies, mid-size businesses, high net worth individuals and entrepreneurs looking to grow their businesses.

Our goal is to minimise your business and personal tax exposure by means of legitimate planning and keeping you aware of the changing requirements of the taxation system in India and abroad.

Corporate tax

We have a highly experienced team of corporate tax professionals to deal with an increasingly complex body of tax legislation. Tax planning plays an important part and our primary objective is to help mitigate the burden of taxation within the confines of the law

Our experience with a broad spectrum of national and transnational clients, engaged in different businesses, gives us a wider understanding of individual business needs.

Our key corporate tax service offerings are:

Corporate tax advisory

Statutory compliance support
Tax diagnostic reviews to identify uncertain tax positions and ensure risk mitigation
Tax withholding health checks
Tax minimisation and optimisation strategies, availability of tax deductions, etc. and other tax planning ideas
Advise and plan optimisation of capital structure and debt equity ratio
Review of applicability of ICDS and related disclosures
Review of Ind-AS applicability and related action points
Review and applicability of POEM

Tax compliance

Assistance in preparation and filing of withholding tax returns
Assistance in preparation and advise on advance tax payments and optimisation
Preparation and filing of corporate tax returns
Preparation and filing of overseas entity tax returns in India

International tax

Our objective is to help businesses achieve global tax efficiency by minimising tax incidence and reducing tax and compliance costs in multiple jurisdictions.

Our international tax services include:

Outbound investment advisory
Outbound due diligence
Advise on International tax treaties entered into by India and related tax planning
Advise on BEPS rules and the multi-lateral instrument entered in to by India
Advise and provide assistance on specific provisions applicable to non-residents such as shipping companies, etc.
Advise on investment treaties signed by India
Assistance with Mutual Agreement Procedure under the tax treaties
Assistance with preparation and filing for applications before the Authority for Advance Ruling

Tax representation and litigation services

Tax representation and litigation in India requires a comprehensive approach involving people with adequate understanding of tax laws and insightful handling of contentious issues. Our services in this area include:

Tax representation before Assessing Officer and other tax authorities during the course of audit or investigation by the revenue authorities
Tax litigation support before Tax Commissioner (Appeals, Dispute Resolution Panel and ITAT)
Tax briefings and support to the external counsel in respect of representation before ITAT/ High Courts/Supreme Court
Advisory on litigation strategy and its implementation
Diagnostic review of litigation history and assistance in litigation risk analysis
Assistance in evaluating sustainability of tax positions and assistance in remedial actions

Indirect tax services

Advisory services

Evaluate tax implications on existing or proposed business transactions
Review contracts and agreements in order to identify the GST impact, from the perspective of Procurement, Manufacturing and Distribution
Assistance in identifying optimal valuation model for related party transactions under GST, while aligning the same with the model adopted under transfer pricing provisions
Evaluate the legal positions adopted and suggest changes, if any, under the GST regime
Assistance to comply with the provisions of anti-profiteering rules under
Advice on matters pertaining to import and export of goods into/from India under the Customs Act, 1962
Assistance in Customs Valuation-related matters with regards to import from related parties
Advice on various incentive schemes pertaining to duty-free import/export of goods or services under the Foreign Trade Policy

Compliance services

Assistance in obtaining registrations under GST or other statutory legislations as required
Verification of input tax credit records and identification of ineligible credits
Review of periodic computation of tax liabilities
Assistance in preparing and filing periodic return(s)
File requisite statutory applications with various authorities

Litigation

Assistance in drafting responses to notices, enquiries and such other communication received from revenue/assessing authorities
Assistance in preparation and filing of appeals against orders received from appellate authorities
Representation before the appropriate authorities and engaging external legal counsel, if required
Filing advance ruling applications with the authorities in order to seek clarification on ambiguous matters

Other services

Conduct due diligence reviews from indirect tax perspective
Conduct health-check reviews and ensure that tax compliances are adhered to
Provide technical assistance and representation services during departmental audits
Assistance in preparation and filing of representations before Advance Ruling authorities and other tax or government authorities
Conduct management/personnel training for clear understanding of relevant GST provisions

Transfer pricing agreement

Compliance

Local transfer pricing compliance documentation for international transactions and specified domestic transactions including:

Functional analysis
Comparability analysis
Industry and business overview

Assistance in obtaining of an Accountant's Report in Form 3CEB
Master File and country-by-country (CbC) reporting

Assistance in preparation of Master File
Assistance in preparation of CbC Report where:

The ultimate parent company is in India
The Indian entity is designated as the Alternative Reporting Entity (ARE)
Indian entity does not have an agreement for exchange of CbC Report with country of foreign parent
Despite having an exchange agreement, country of foreign parent (or ARE) fails to share CbC Report

Assistance in communicating and liasoning with the relevant prescribed authorities whenever required

Advisory

Assistance in setting up business/operational model
Restructuring of existing business model to build tax/commercial efficiencies
Due diligence report (DDR) assistance from transfer pricing perspective in order to ensure that the business model and pricing arrangements of target acquisition are defensible
Assistance in corporate governance under Companies Act, 2013 and SEBI regulations

Identification of related parties
Analysing the identified RPT as to:
Whether the transactions are in the ordinary course of business; and
Whether the transactions are proposed to be undertaken on arm’s length basis
Analysing and evaluating various approvals that may be required (i.e. Audit Committee, Board of Directors, shareholders etc.) for each of the RPT under the Companies Act 2013 and SEBI regulations
Review-related party compliances under the Companies Act on a quarterly/half-yearly/annual basis
Present our analysis at board meetings to assure Directors that compliances are in order

Review of deemed international transactions
Assistance in preparing profit attribution studies
Assistance in preparing global transfer pricing policy document
Supply chain restructuring
Structuring management fee payments, royalty payments, inter-company financing arrangements

Dispute Avoidance/Resolution

Assistance in representation before:

Transfer Pricing Officer
Commissioner of Income Tax (Appeals)
Dispute resolution panel
Appellate tribunals

Drafting of submissions, appeals and letters to the revenue/appellate authorities
Tax briefings and providing external support to external counsels for representation before High Courts and Supreme Court
Assistance in Advance Pricing Agreements (APA) proceedings
Assistance with mutual agreement procedures (MAP)
Assistance in relation to Safe Harbour application