Tax & Transaction Advisory

Navigate every
border, every
tax, every deal

India's tax and foreign exchange landscape is among the most complex in the world. We advise businesses and HNIs on cross-border structuring, FEMA compliance, international taxation, and transaction advisory — with clarity and precision.

Cross-Border Transactions
DTAA Planning
FDI Regulations
FEMA Compliance
Direct Tax
Indirect Tax
Book a Consultation Explore Services
Income Tax Act
GST / Indirect Tax
DTAA Treaties
FEMA Regulations
FDI Policy
Transfer Pricing
Our Services

Expert advisory across
every dimension of tax

01
Cross-Border Transaction Advisory
International Structuring
International
Cross-border transactions between India and other jurisdictions require careful navigation of exchange control, tax treaty positions, transfer pricing rules, and regulatory filings. We provide end-to-end advisory to ensure your international transactions are structurally sound and fully compliant.
Inbound Investment Structuring
Advising foreign companies and investors on the optimal structure for bringing capital into India — equity, debt, hybrid instruments — considering tax efficiency and repatriation.
Outbound Investment Advisory
Structuring overseas direct investment (ODI) by Indian companies and individuals, including Overseas Investment Rules, 2022 compliance.
Transaction Due Diligence
Tax and regulatory due diligence on cross-border M&A, joint ventures, and international service agreements.
Structuring of inbound FDI
ODI / overseas investment compliance
Cross-border loan / ECB structuring
Repatriation planning
Joint venture structuring
Treaty-based holding structures
02
Direct & Indirect Tax Advisory
Domestic Taxation
Direct + GST
India's two-tier tax system — direct tax (income tax, corporate tax, TDS) and indirect tax (GST, customs) — each demands specialist expertise. We provide proactive advisory to minimise your tax burden while ensuring full compliance.
Corporate Tax Planning
Optimal corporate tax structure selection, deduction planning, MAT/AMT analysis, and advance tax management for companies.
GST Advisory & Litigation
GST structuring for complex transactions, ITC eligibility opinions, place-of-supply advisory, and GST audit / department litigation support.
Tax Assessments & Appeals
Representation before Income Tax Assessing Officers, CIT(A), ITAT, and High Courts for assessment, reassessment, and penalty proceedings.
Corporate tax structuring
MAT / AMT planning
TDS compliance & advisory
GST transaction structuring
Customs & import duty advisory
Tax litigation & representation
03
International Taxation & DTAA
Treaty Planning
90+ Treaties
India has Double Taxation Avoidance Agreements with over 90 countries. Correctly applying treaty provisions — and avoiding GAAR / PPT challenges — requires deep expertise. We advise on the most tax-efficient international structures, withholding tax positions, and treaty entitlement.
DTAA Position Advisory
Analysis of treaty provisions, residency tie-breaker rules, withholding tax rates, and beneficial ownership requirements for MNCs and NRIs.
Transfer Pricing
Arm's length pricing analysis, transfer pricing documentation (TP study / Master File / CbCR), and representation in TP assessments.
GAAR & BEPS Advisory
Principal purpose test analysis, BEPS action plan compliance, and substance-based structuring to ensure international tax positions are defensible.
💡
Why DTAA matters: Without proper treaty planning, cross-border service fees, dividends, royalties, and capital gains can be taxed in both countries — often at rates of 20–40%. Correct treaty application can reduce withholding tax to 5–15% or even zero in some cases.
04
FDI Regulations
Foreign Direct Investment
RBI / DPIIT
India's FDI framework — governed by the Foreign Exchange Management Act, DPIIT FDI Policy, and sector-specific regulations — determines how foreign capital can enter India, the permissible sectors, and the applicable conditions. We guide foreign investors through every step.
Automatic Route Advisory
Identifying eligible sectors and conditions for automatic route FDI, pricing guidelines, and post-investment reporting to RBI.
Government Approval Route
Preparation and filing of FIPB/DPIIT approval applications for restricted sectors including media, telecom, and defence.
Sectoral Compliance
Sector-specific FDI cap analysis — retail, pharma, real estate, NBFC, insurance — and ongoing compliance monitoring.
FC-GPR & FC-TRS filings
Pricing certificate (CA certificate)
Downstream investment compliance
Press Note analysis
Compounding applications
Annual return on FLA
05
FEMA Regulations
Foreign Exchange Management
FEMA · RBI
The Foreign Exchange Management Act governs all cross-border financial transactions by Indian residents and companies. Non-compliance carries severe penalties. We ensure every foreign currency transaction, investment, and remittance your business makes is FEMA-compliant.
Current Account Transactions
Advisory on permissible current account transactions, remittance limits (LRS), trade payments, and royalty / fee remittances.
Capital Account Transactions
ECB (external commercial borrowing), ODI, issue and transfer of shares to / from non-residents, and property transactions.
NRI Transaction Advisory
NRE/NRO account management, repatriation of sale proceeds, gift and inheritance transactions, and property purchase advisory for NRIs.
LRS compliance & documentation
ECB documentation & reporting
FEMA compounding applications
Import-export FEMA compliance
NRI repatriation advisory
RBI liaison & correspondence
Why India is Complex

Multiple regulators.
One wrong move costs.

Cross-border transactions in India involve the Income Tax Act, FEMA, RBI Master Directions, DPIIT FDI policy, Companies Act, and sector-specific regulators — often simultaneously. An error in any one layer can trigger penalties, demands, or transaction unwinding.

🏛️
Reserve Bank of India (RBI)
FEMA, ECB, FDI reporting, NRI transactions
📊
Income Tax Department
Withholding tax, DTAA, transfer pricing, GAAR
🏢
DPIIT / Ministry of Finance
FDI policy, sectoral caps, press notes
💰
GSTN / CBIC
Import of services IGST, cross-border GST
⚖️
MCA / NCLT
Cross-border mergers, company law compliance
Our Expertise

Why clients choose
Counsel & Capital

🔍
Deep Regulatory Knowledge
Our team tracks RBI circulars, CBDT notifications, and DPIIT press notes in real-time — so you're never caught by a rule change.
🌍
International Experience
Served clients from the US, UK, Singapore, UAE, Europe, and Southeast Asia entering and operating in India.
🔗
Integrated Legal & Tax
Tax structuring and legal documentation go hand-in-hand. Our CA and lawyer work on the same engagement — no gaps.
📋
Documentation Excellence
Transfer pricing studies, DTAA benefit claim forms, FC-GPR filings — our documentation is clean, complete, and defensible.
⚡
Responsive Advisory
Tax questions don't wait for quarterly review meetings. We respond quickly, especially on time-sensitive transactions.
🛡️
Litigation-Ready
If a tax position is challenged, our in-house legal team is ready — from written submissions to representation at ITAT.
Complex cross-border transaction?
Let's navigate it together.
Free 30-minute consultation with our tax advisory team.
Book Consultation
Get in touch

Ready to optimise your
tax position?

From routine compliance to complex transactions — book a free 30-minute consultation with our tax team.

Call us
+91 80763 04979
Email
hello@counselandcapital.in
Office
Greater Kailash-2, New Delhi