Tax & Regulatory Services

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TAX & REGULATORY SERVICES

Our team brings together technical specialists, industry experts, and senior professionals with extensive experience in international taxation and dealing with tax authorities. We provide end-to-end support across areas such as transfer pricing compliance and documentation (benchmarking, Form 3CEB, local file, master file, and country-by-country reporting), advance pricing agreements (APAs), audits, and related advisory services. We also assist businesses with cross-border structuring, inbound and outbound investments, and tax-efficient strategies to support global expansion.

Direct Tax & Regulatory Services

CORPORATE TAX ADVISORY

Understanding Indian Income-Tax Law can be complex, especially with the introduction of concepts such as Indirect transfers, GAAR and more. At Bhatia and Bhatia, we strategically leveraged the tax and regulatory developments to benefit your business activities. Our services include the following:

  • Corporate & Individual Tax Returns: Assisting in filing of tax return for all type of assesses (i.e. Individuals, LLP, partnership firms, AOP, BOI etc.).
  • Tax Audit: Conducting Tax Audits under Section 44 AB of the Income Tax Act, 1961.
  • Tax Planning and Strategies: Developing the strategies for profit & dividend repatriation and business optimisation strategy for both Indian and overseas companies.
  • Corporate Restructuring: Advising on corporate restructuring, amalgamation, demerger, slump sale, divestitures and other significant corporate moves.
  • Transaction Opinion: Providing opinions on various transactions and provisions of Income Tax Act from domestic law and tax treaty perspectives.
  • Employee Remuneration Structuring: Advice on structuring remuneration packages to minimize the tax liability and maximize their take-home pay, ensuring the entire remuneration is allowed as business expenditure for the employer.
  • POEM Review: Reviewing and assessing the applicability of the Place of Effective Management (POEM).
  • Pillar I and Pillar II Implications: Advising on the implications of proposed international tax concepts of Pillar I and Pillar II.

Tax Litigation and Representation Services

Tax disputes can be stressful, costly and prolonged. We offer comprehensive representation and guidance, including:

  • Representation before Indian tax authorities: Representing clients before the Indian tax authorities and appellate forums, including the Commissioner (Appeals), Appellate Tribunals.
  • Search and Seizures cases: Representing clients before the Investigation wing in search and seizure cases.
  • Dispute Resolution Panel: Representation before DRP.
  • Strategic Guidance: Providing strategic guidance for approaching potential tax controversies.
  • High Courts and Supreme Court: Assisting in the preparation and representation of cases before the High Courts and the Supreme Court of India.

Withholding Tax

Compliance with TDS (withholding tax) regulations is crucial for both domestic and international transactions. Our specialized services include:

  • E-TDS return filing: Assisting in filing quarterly withholding tax returns.
  • Withholding Tax Opinion: Providing an opinion on the applicability of withholding tax on various foreign remittances as per the Indian Income Tax Act and DTAA.
  • Consultancy and Certification: Consulting and certifying foreign remittances according to Section 195 of the Income Tax Act, 1961 or as per DTAA provisions.

Registration and Other Taxation Services

We assist with a range of compliance activities under the Income Tax Act, including:

  • PAN and TAN: Obtaining Permanent Account Number (PAN) and Tax Deduction & Collection Account number (TAN).
  • Lower Withholding Tax Certificates: Obtaining lower withholding tax certificates for both resident and non-resident assesses.
  • Certificates for Overseas Remittance: Issuing certificates under Section 195 for overseas remittances.
  • Expatriate Compliances: Ensuring compliance for expatriates in India.

INTERNATIONAL TAX

Our team brings together technical specialists, industry experts, and senior professionals with extensive experience in international taxation and dealing with tax authorities. We provide end-to-end support across areas such as transfer pricing compliance and documentation (benchmarking, Form 3CEB, local file, master file, and country-by-country reporting), advance pricing agreements (APAs), audits, and related advisory services. We also assist businesses with cross-border structuring, inbound and outbound investments, and tax-efficient strategies to support global expansion.

Transfer Pricing

Indian tax laws mandate an annual evaluation to ensure that companies with overseas group entities comply with the “arm’s length” principle in their transactions, including sales, purchases, services, loans, management fees, and royalty payments. These regulations necessitate a detailed transfer pricing (TP) study by the company and a certification by an external auditor.

We offer the following services:
  • Help in establishing an appropriate arm’s length policy and compiling documentation that aligns with the global transfer pricing approach and BEPS Action Plan recommendations.
  • Conduct benchmarking analysis to determine the arm’s length nature of the Group’s transfer pricing arrangements.

Drafting/ Reviewing Inter-Company Agreements

Assist in drafting and reviewing inter-company agreements to ensure compliance with DTAA provisions, arm’s length pricing (ALP), and overall tax optimization, while aligning with requirements under Direct Tax, GST, FEMA, and other regulatory frameworks.

Transfer Pricing Compliance

  • Assistance in maintaining contemporaneous transfer pricing documentation based on the applicable TP regulations.
  • Issuance of Accountant’s report in Form No. 3CEB.
  • Assistance in preparation of Country-by-Country reporting, global master file and local master file, based on the BEPS Action Plan 13 and local transfer pricing regulations, respectively.

Managing Transfer Pricing Controversy

  • Assist in developing and executing a comprehensive tax litigation strategy.
  • Represent clients before the Transfer Pricing Officer (TPO), Assessing Officer (AO), Commissioner of Income Tax – Appeals (CIT(A)), Dispute Resolution Panel (DRP), and Income Tax Appellate Tribunal.
  • Provide tax briefings and external support to counsels for high-level litigation representations.
  • Aid in securing Advance Pricing Agreements (APA) and assist with tax rulings.
  • Offer support in the Mutual Agreement Procedure (MAP).
  • Help interpret and implement Safe Harbour Rules.

Regional Benchmarking

  • Support in performing benchmarking analysis per local documentation requirements using global databases.
  • Provide regional benchmarks for royalty and commission rates using the RoyaltyRange database.
  • Assist in determining arm’s length margins using international databases for companies operating in the African, Asia-Pacific, American, European, and Middle Eastern regions.

Transfer Pricing Advisory Services

  • Assess the current compensation model and provide insights from an arm’s length perspective.
  • Aid in creating a transfer pricing policy that aligns with both business objectives and arm’s length standards.
  • Review the existing transfer pricing policy to identify potential risks and ensure compliance with local regulations.
  • Assist in transfer pricing due diligence from both corporate tax and documentation perspectives.
  • Mitigate potential transfer pricing risks for the group.
  • Support in drafting and reviewing agreements for multinational enterprises.

Advisory Services

  • Advising new structure/ alternate operating models and assistance in development of a sound business strategy.
  • Structuring management fee payments, royalty payments, inter-company financing arrangements.
  • Assistance in preparing profit attribution studies.
  • Advise on International tax treaties entered into by India and related tax planning.
  • Advise on BEPS Action Plans and the multi-lateral instrument entered into by India.
  • Analysis of the various vehicles available for the Indian setup in terms of a limited liability company (LLC), limited liability partnership (LLP) and branch office/ project office.
  • Review of the potential tax risks and compliances associated with the set-up of an online business in India (including PE implications and reviewing arrangement in light of BEPS Action Plans).

Our Indirect Taxation team provides assistance on numerous and never-ending tax compliances, opinions and practical advisory in complicated tax issues, handling complex appeals and representations, GST Audits, Customs, foreign trade policy related matters, assistance in Refund and Audit issues. We have the necessary skills to blend practical business & commercial insights with tax & regulatory knowledge to identify effective transaction structures, to find exposures and suggest appropriate ways forward. Our highly experienced team of professionals has been conducting GST audits, advising, and assisting companies across a spectrum of matters relating to Tax Advisory and Planning, Compliance and Representation Services.

  • GST Audits
  • GST Health Check Diagnostics
  • Litigation Services
  • Representational Services
  • Computation & Return
  • Regulatory compliances
  • SVB Registration & Amendment
  • AEO Registration & Renewal
  • Bonded Manufacturing Facility (MOOWR) Registration & Compliances
  • Finalization of BOEs & EDD / CEPA Refunds
  • Customs Advisory & Representation
  • Valuation & Classification of HSN Codes
  • Export Incentives (SEIS, MEIS, RoTDEP, EPCG, PLI, AA, DFIA etc.)
  • Foreign Trade Policy
  • Tax Planning
  • Advance Ruling
  • Compliance Monitoring & Support

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