In order to assist clients for attainment of maximum benefits of taxation laws within their framework, we provide legal advice on provisions contained under the Indian Income Tax law and a particular Double Tax Avoidance Agreement in relation to various kinds of international transactions having extra-jurisdictional ramification.

In relation to DTAAs, we provide legal counselling on various kinds of cross border structuring / taxation issues relating to inbound and outbound foreign investment and double taxation aspects relating to the following :

  • Permanent establishment.
  • Income from immovable property.
  • Business profits.
  • Associated enterprises.
  • Taxation aspects of various kinds of incomes like interest, royalties, technical services, management fees, capital gains, and rental income.
  • Dependent and independent personal services.
  • Directors fees.
  • Withholding tax.
  • Inbound and outbound transactions.
  • Branch, liaison and project offices.
  • Tax credits.
  • International mergers and acquisitions.
  • Service contracts.
  • Passive foreign investment corporations,
  • Business connection and place of management.
  • Residential status and beneficial ownership.
  • Secondment of employees.
  • Thin capitalization, force of attraction, hybrid entities, non discrimination, mutual agreement procedures, tax sparing etc.

In view of the fact that almost every financial decision has tax implications, incidence of tax planning and foresight of management is crucial for corporate, we give tax advice to companies on various business and financial decisions commencing from its setting up and encompassing its corporate restructuring exercises like amalgamation, demerger, slump sale, takeovers, collaborations, financial management, employee remunerations and specific managerial decisions.

Additionally, we also advice individuals (residents and non residents), firms, HUFs, cooperative societies, private and charitable trusts and funds on diverse matters under various heads of Indian Income Tax Act, such as salaries, income from house property, profits and gains from business or profession, capital gains and income from other sources. The scope of services include advising on tax issues relating to residential status, business connections, agricultural income, salaries, allowances and perquisites, house rent, donations, revenue and capital receipts, capital and business expenditure, interest on securities, dividend, clubbing of income, set off and carry forward of losses, deductions, rebates, conversion from one form of entity to another, tax deducted at source, advance tax, wealth tax etc to assist them in efficient tax planning.

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