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
Income Tax Act
GST / Indirect Tax
DTAA Treaties
FEMA Regulations
FDI Policy
Transfer Pricing

Expert advisory across
every dimension of tax

01
International Structuring
Cross-Border Transaction Advisory
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.
International
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
Domestic Taxation
Direct & Indirect Tax Advisory
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.
Direct + GST
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
Treaty Planning
International Taxation & DTAA
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.
90+ Treaties
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
Foreign Direct Investment
FDI Regulations
India's FDI framework — governed by FEMA, the DPIIT FDI Policy and sector-specific regulations — determines how foreign capital can enter India, the permissible sectors and applicable conditions. We guide foreign investors through every step.
RBI / DPIIT
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 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
Foreign Exchange Management
FEMA Regulations
FEMA 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.
FEMA · RBI
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

Multiple regulators.
One wrong move costs.

Cross-border transactions in India involve the Income Tax Act, FEMA, RBI Master Directions, DPIIT FDI policy, the 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

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