International Tax Advisory
International Tax Advisory comprises of applicability of Income Tax Act along-with provisions of Double Taxation Avoidance Agreements (DTAA). International Tax Advisory also considers tax relief on tax paid in foreign country.
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- FDI (Foreign Direct Investment) norms and its limit for investment in specified sector, also need to comply with FDI norms country wise considering its automatic route or approval route
- Cash / Profit Repatriation tax as per country wise need to be analysed and the same to be designed in such a manner to carry out effective tax planning country wise
- Financing techniques should be tax effective and thin capitalisation rules
- Understanding and deriving maximum benefit from the tax treaties existed between the countries, instead of adopting normal tax structure tax treaties can become beneficial.
- Understanding various exemptions and subsidies given by different countries, mapping the same with the country wise location of the business and to drive maximum benefit from exemptions / relief measures / capital subsidy etc.
- Tax rulings must also be interpreted and the same may also be taken into consideration if the tax laws are not clear or silent on specific issues.
- Companies having global presence must develop tax efficient structure aimed at mitigating tax leakage
- Ascertain the applicability and mitigation of withholding taxes on cross border payments such as interest, royalties, dividends or branch payments.
- Evaluating the foreign tax credit and mapping it with tax treaties if applicable, allocation of expense principles, permanent establishment and Tax Residency certificates (TRCs)
- Cross Border Treasury and finance must me tax efficient and besides that there must be ease in repatriation of profits.
- Analyse and evaluate the Intellectual Property Rights (IP Rights) and designing & structuring the IP transfer in tax efficient manner.