1. Direct Taxation

1.1. Corporate tax advisory

It is generally believed that Indian Income-Tax Law offers a hostile reception. Further, with the introduction of concepts such as Indirect transfers, GAAR and others, the Tax challenge is likely to escalate.

We understand the impact of developments in tax and regulatory aspects and strategically use them to the benefit of business activities conducted by you.

Our services include the following:

Corporate & Individual Tax Returns: We assist all assesses (i.e. Individuals, LLP, partnership firms, AOP, BOI etc.) in filing of Income tax Returns.
Tax Audit under Section 44 AB of the Income Tax Act, 1961.
Tax planning, strategies for profit & dividend repatriation and business optimisation strategy for Indian and overseas companies.
Corporate restructuring: We advise clients on corporate restructuring, amalgamation, demerger, slump sale, divestures and other major corporate moves.
Providing opinions on various transactions and provisions of Income Tax Act from domestic law to tax treaty viewpoint.
Advice on structuring remuneration packages for employees and on cost saving opportunities so as to minimise the tax bill in the hands of employees and maximise their take home pay, and also ensure that the entire remuneration is allowed as business expenditure for the employer.
Advance tax calculations and deposit on quarterly basis and deposit of self-assessment tax and tax on regular assessments etc.
Review and applicability of POEM.

1.2. Tax Litigation and Representation Services

Tax disputes can be stressful, costly and can take years to resolve. We provide following services:

Representation before Indian tax authorities and various appellate forum such as Commissioner (Appeals), Appellate Tribunals.
Representation before Investigation wing in search and seizure cases
Representation before The Dispute Resolution Panel (DRP)
Providing strategic guidance for approaching potential tax controversies
Assistance in preparation and representation of case before High Courts and Supreme Court of India

1.3. Withholding Tax

TDS or withholding tax has become an important compliance for domestic and international withholding taxes. We specialize at consultancy on TDS matters and Withholding Audits. Income Tax provisions belonging to TDS or tax withholding are becoming stringent day by day.

We provide following services in this regard:

E-TDS return filing
Opinion on Applicability of withholding tax on various foreign remittances as per Indian Income tax Act / DTAA.
Consultancy and certification for making foreign remittances according to the provisions of section 195 of the Income tax Act, 1961 or as per Double Taxation Avoidance agreements (DTAA).

1.4. Registration and Other Taxation services

Compliance of Income Tax Act require a wide range of activities, we provide following services to help in other compliances:

Obtaining Permanent Account Number (PAN), Tax Deduction & Collection Account number (TAN)
Obtaining Lower Tax Certificate both for Resident and Non-Resident assesses.
Issuance of certificates u/s 195 required for the Overseas Remittances purposes from time to time.
Compliances for Expatriates in India.

2. International Tax

Our professional team consists of technical and industry experts, senior resources with experience in dealing with the tax authorities and highly skilled professionals with exposure to international taxation. We assist entities in complying with the transfer pricing compliance requirements, which would entail conducting a transfer pricing benchmarking, transfer pricing policy analysis, filing of Form 3CEB, preparation of local TP documentation and assisting with transfer pricing audit and other related advisory services.

2.1. Transfer Pricing

Indian tax laws require an annual assessment of whether companies with overseas group entities meet the “arm’s length” requirement in their transactions (sales, purchases, services being provided, loans, management fee, royalty payments). Regulations require both a detailed (TP) study by the company and a TP audit report by an external auditor.

We assist clients in following services:

Assistance in framing adequate arm’s length policy and compiling documentation in alignment with global transfer pricing approach that meet recommendations under BEPS Action Plans too.
Conducting benchmarking analysis for determination of the arm’s length nature of the transfer pricing arrangements of the Group.

2.2. Drafting/ Reviewing inter-company agreements

Assistance in drafting and reviewing the inter-company agreements that helps clients in meeting the overall objective of the Group and to align the agreements from direct tax, indirect tax and regulatory perspective.

2.3. Transfer pricing compliance

Assistance in maintaining contemporaneous transfer pricing documentation based on the rules and regulations provided under the Indian transfer pricing regime.
Issuance of Accountant’s report in Form No. 3CEB
Assistance in preparing master file and Country-by-Country Report (“CbCR”) based on the Indian transfer pricing regulations and BEPS Action Plan 13.

2.4. Managing Transfer Pricing Controversy

Support in preparation of sound tax litigation strategy and its implementation.
Representation before the Transfer Pricing Officer (“TPO”), Assessing Officer (“AO”), Commissioner Appeals (“CIT(A)”), Dispute Resolution Panel (“DRP”), Appellate tribunals.
Tax briefings and providing external support to counsels for representation in front of high-level litigation authorities.
Assistance in obtaining Advance Pricing Agreements (“APA”) and helping with tax rulings.
Assistance in Mutual Agreement Procedure (“MAP”).
Assistance in understanding and implementing Safe Harbour Rules.

2.5. Regional benchmarking

Assistance in conducting benchmarking analysis, as required under local country documentation requirements using international databases such as OneSource and Orbis.
Providing regional benchmarks for royalty, commission rates, etc. using RoyaltyStat database.
Assistance in determination of arm’s length margin using international databases for the companies operating in African region, Asia-Pacific region, American region, European region.

2.6. Transfer pricing advisory services

Evaluating existing compensation model and comment from an arm’s length perspective.
Assistance in devising transfer pricing policy that meets business objectives as well as arm’s length criteria.
Review of the existing transfer pricing policy in order to analyse potential risks and to align it with local country-specific requirements.
Mitigation of potential TP risks for the group.

2.7. 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 in to 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).

3. Indirect Taxation and Foreign Trade Policy

3.1. Goods & Services Tax compliances

India’s biggest indirect tax reform has been the introduction of Goods and Services Tax (GST) which was implemented with effect from 1^st July 2017. GST is an organization-wide transformational change that has impacted the entire value chain of operations, including procurement, manufacturing, distribution, warehousing, sales and pricing.

GST has been envisaged as a more efficient tax system, neutral in its application and attractive in distribution. We provide following services:

Registration, modification or amendment with the GST Authority
Regular Compliance of GST including filing of returns within time
Assistance in filling application of Letter of Undertaking (LUT) for export of goods & services.
Filling GST refund application and representing clients before the authorities
Advisory services with respect to GST matters
Conducting Health check reviews / Due Diligence Check as per the needs of the clients.
Interpretation of GST Act and specific sections based on clients’ industry, products, exporter/importer status and other unique circumstances
Transaction Planning to deal with GST Implications.

3.2. Customs and Trade solutions

Advice on customs related matters including strategic consulting, classification, determining rate of customs duty, valuation, benefits under notifications and duty free schemes, import-export procedures etc.
Preparation of replies to show-cause notices, drafting of appeals in customs matters at all levels, preparation and filing of advance rulings applications and representation in relation thereto.
Filing applications before Policy Relaxation Committee in relation to the DGFT matters and representation in relation thereto.
Preparation and filing of representations before various bodies and representation in relation thereto;
Assistance in relation to brand rate fixation, obtaining Authorised Economic Operator certification, Import Export Code, Registration Cum Membership Certificate etc
The Special Valuation Branch (“SVB”) is a unit of the Indian custom authorities that investigates valuation of goods during imports between related parties. A special relationship between an Indian importer and a foreign supplier may impact the transaction price of the import and thereby affect the customs duty imposed on such transaction. SVB’s function is precisely to examine the impact of such relationship on the invoice value of the imported goods. Multi-national corporations in India are supposed to pay the duties on the price of the goods derived by special valuation Branch (SVB) of customs. We assist in obtaining registration of SVB with custom department.

3.3. Foreign Trade Policy

Our firm will assist you to provide services with respect to Foreign Trade Policy in place. This Act is concerned with the development and regulation of foreign trade by facilitating imports into and augmenting exports from India. FTP is a set of guidelines and instructions formulated by Central Government covering a period of 5 years. Our team undertakes following schemes covered in policy of 2015-2020. Our services broadly covers following:

Merchandise Exports from India Scheme (MEIS)/ Service Exports from India Scheme (SEIS)

Government of India designed both the schemes with the aim of making India’s export products/ services more competitive in the global markets. The rewards are given based on net foreign exchange earned by the Company in India the reward is awarded in form of duty scrips which are freely transferrable in market. Thereby, we assist companies in filing of applications with DGFT and thereby make representation with required submission as and when required by the authorities.

Electronic IEC

Import Export Code (IEC), or in casual terms, import/export permit is mandatory for carrying out exports and imports from/to another country. DGFT has facilitated the online filing of IEC application. Our team ensures the obtaining of IEC as well as its updation electronically.

3.4. EPCG

EPCG Scheme allows import of capital goods for pre-production, production and post-production at Zero customs duty. Alternatively, the Authorization holder may also procure Capital Goods from indigenous sources in accordance with provisions of paragraph 5.07 of FTP. The EPCG scheme allows duty free import of capital goods new capital goods at NIL Customs duty as against the normal total of 26.428%, thus providing a total duty saved of import value. EPCG comes with condition that export obligation to be fulfilled that equivalent to 6 times of duty saved, to be done over a period of 6 years. The export obligation needs to be fulfilled by the license holder. We provide consultancy solutions for taking maximum benefits with import export business. We take care of DGFT legal documentation, preparation of EPCG Application, representation and coordination with DGFT and other associated Government Departments till you finally get the EPCG license.