Practice Areas

Tax

We are one of the few law firms in India that has full-service tax capabilities and offers end-to-end advice on matters ranging from establishment of entities in India to the minutest of operational issues.  From assisting clients in establishing entities in India to addressing the minutest operational tax issues, we offer strategic guidance at every stage of the business lifecycle.  Our team of experienced tax attorneys is well-versed in both direct and indirect tax laws, enabling us to provide holistic solutions to our clients’ tax challenges.

We are committed to delivering excellence in tax advisory services.  Our dedicated team of tax professionals combines technical expertise with a client-centric approach, ensuring that our clients receive tailored solutions that meet their unique needs and objectives.  With a focus on innovation and continuous improvement, we strive to be the trusted partner our clients rely on for all their tax-related needs.

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Offshore and Onshore Tax Matters

Our team of seasoned tax professionals excels in advising clients on offshore tax structuring, tax treaties, and tax implications of cross-border transactions.  Whether our clients want to invest in India or expand their business globally, we provide tailored solutions to optimize tax efficiency and minimize risks.

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Strategic Tax Structuring

We leverage our expertise to design tax-efficient structures that align with our clients’ business objectives.  From optimizing capital gains tax to utilizing tax incentives and exemptions, we help clients navigate the complexities of Indian tax laws while ensuring compliance and minimizing tax exposure.

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Transfer Pricing and Compliance

Our firm offers specialized transfer pricing services, assisting clients in implementing robust transfer pricing policies, preparing documentation, and navigating transfer pricing audits.  We help clients mitigate transfer pricing risks and maintain compliance with local regulations.

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Specialized Tax Advisory

In addition to direct and indirect tax matters, we provide specialized tax advisory services covering withholding taxes, permanent establishment issues, employee benefits taxation, and tax holiday schemes.  Our team stays abreast of the latest developments in tax laws and regulations, offering strategic advice to help clients optimize their tax positions and mitigate potential risks.

Recent Transactions in Tax

  • ARM LLC, USA, on Indian tax withholding advice with respect to its UAE joint venture being contemplated with an Indian entity with which ARM LLC already had an existing joint venture.
  • Aims Impex Private Limited on tax structuring in a M&A deal involving sale of an Indian chemical manufacturing business to another Indian strategic buyer.
  • Pillsbury LLP on certain offshore transaction structure alternatives and the Indian tax consequences relating to capital gains tax, corporate tax and stamp duty issues, indirect transfer tax provisions, and their interplay with the general anti avoidance rules.
  • McGill USA on Indian tax issues in relation to the transfer of shares of an Indian company from a non-resident to another non-resident, valuation requirements as per the Indian tax rules, calculation of capital gains tax liability and tax withholding requirements, and whether gifting of the shares could be a workable option.
  • Bär & Karrer AG, Switzerland, on the treatment of shares, options, dividend pay outs or cash to be allocated to the client’s Indian subsidiary employees; applicability of social security taxes; valuation requirements; and payroll obligations in the process of adopting an equity participation plan for its future Swiss and Indian subsidiary employees.
  • NapCloud, USA, on tax issues and transfer pricing.
  • Zephyr Software Holdings, USA, on a complex offshore tax restructuring transaction.
  • Gibtele on permanent establishment and employee tax issues in relation to employment of Indian residents through a professional employer organization in India.
  • Govecs Group, Germany, on tax structuring, permanent establishment risks and other issues for the Indian entity regarding their proposed activities in India.
  • DyStar Holding Pte Limited, Singapore, on royalty fee withholding tax and penalties on account of non-payment.
  • Linode LLC, USA, on tax and transfer pricing issues, as also on the Advance Pricing Agreement (APA) regime. 
  • Sysdig, Inc. on permanent establishment and employee tax issues. 
  • Builder Homesite, Inc. on tax structuring, intermediate holding company structures and transfer pricing issues in relation to acquisition of Indian entities.
  • Baidu (Hong Kong) Limited on tax issues in relation to the establishment of a subsidiary in India.
  • NantHealth Inc. on tax issues in relation to the sale of its Indian subsidiary to Allscripts Healthcare Solutions, Inc.
  • Grab Taxi Holdings Pte Ltd. on a proposed tri-partite joint venture arrangement with an Indian company and a foreign company.
  • United Retirement Plan Consultants, Inc. on their investment and tax structuring in India in relation to the proposed acquisition of MGA Consultants in Baltimore, Maryland, for cash and stock.
  • Hydrochem LLC, USA on the requirements of withholding tax certificate in relation to an agreement with an Indian company to provide certain services.
  • Nippon Soda Co. Limited on complex Indian tax and permanent establishment issues related to the launch of a business platform in India to promote its product sales.
  • Lumiata, Inc. on transfer pricing and permanent establishment issues in relation to its Indian subsidiary that was owned by one of the client’s US employees and an Indian resident, and the client wanted to transfer ownership of the Indian subsidiary from the employee and the Indian resident to itself.
  • Andreas Neocleous and Co LLC on a matter following major amendments to the India-Mauritius and India-Singapore tax treaties.
  • Tavistock Corporation (in conjunction with Tiger Woods Foundation) on Indian withholding tax issues in respect of sponsorship payments from India to the USA.
  • CPA Australia Limited in connection with tax and permanent establishment issues, and regulatory concerns on its proposal to appoint an agent in India to promote and market its activities in India.