Cross border taxation has grown leaps and bounds in terms of its complexity and litigation thanks to ever-evolving business models and emergence of virtual market place without boundaries. With the globalisation and integration of economies large corporations are operating in different tax regimes with each one of them vying for their share of the corporations profit pie in taxes.India, being one of the fastest growing economies, has its own set of challenges in grappling with this change and has been consistently evolving the cross border tax and regulatory landscape. India has signed more than 130 agreements globally including 90+ DTAAs to eliminate double taxation. However with the advent of Multilateral Instruments (MLI), interpretations on cross border transactions are bound to get complex.

With our focus, understanding and business interpretation, forecast on issues of International Taxation becomes facile for our client. We work closely with the regulators to understand the spirit of the regulations and ensure our clients stay ahead of their obligations. Our team ensures that assessments and litigations are handled in the most efficient manner possible.

We offer following assistance in International Taxation:

• Identification of Place of effective management (POEM) through test residency test.
• Advice on Base Erosion and Profit Shifting (BEPS) rules and the multi-lateral instrument entered in to by India.
• Applicability of BEPS and GAAR for international tax structures.
• Advice on equalisation levy and other forms of digital payments.
• 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.