International Tax & Transfer Pricing

International Tax & Transfer Pricing

International tax is complex and fast-moving. Our practice covers everything from day-to-day withholding tax certifications to multi-jurisdictional transfer pricing documentation, PE risk management and treaty planning — giving MNCs and cross-border businesses the certainty they need.

Transfer Pricing

• TP Documentation & CbCR Preparing Local File, Master File and Country-by-Country Reports as required under Indian TP regulations, supported by robust benchmarking studies using international databases.
• Advance Pricing Agreements & BEPS Negotiating APAs with tax authorities to secure certainty on intercompany pricing, alongside full BEPS Action Plan compliance including country-by-country reporting.
• TP Audit Defence Building and presenting strong TP positions during audits, and managing dispute resolution through MAP and mutual agreement procedures.

Cross-Border Tax Advisory

• PE Risk & DTAA Planning Analysing Permanent Establishment risks for foreign companies in India, and structuring transactions to optimise available treaty benefits under applicable DTAAs.
• Withholding Tax & 15CA/CB Issuing Form 15CB certificates and filing Form 15CA for all foreign remittances — covering royalties, fees, dividends and loan repayments to non-residents.
• Outbound Investment & Repatriation Advising Indian companies on overseas investments, foreign subsidiary structures and tax-efficient repatriation of profits back to India.