Direct Tax

Domestic and International Tax Advisory

• Strategic tax planning
• Tax implications on the cross-border transactions, including place of effective management (POEM) analysis and permanent establishment (PE) analysis
• Tax treaty eligibility and base erosion and profit shifting (BEPS) measures
• Tax efficient fund-raising repatriation
• Regulatory approvals and registration

Transfer Pricing Services

• Design and planning including structuring related party arrangements to ensure compliance and efficiency
• Transfer pricing documentation support
• Tax efficient supply chain advisory
• Representation during audits and litigation support

Expatriate Related Services or Global Mobility Services

• Pre-arrival advisory & exit compliance services
• Tax compliance for expatriates including structuring compensation for maximising tax benefits
• Identifying the permanent establishment risk and addressing BEPS concerns for foreign companies
• Structuring Employee Stock Options (ESOPs) tax-efficiently for employers & employees, advisory on tax liabilities arising from ESOP issuances

Dispute Resolution Mechanism or Representation Services

• Drafting appeal documents and preparing case strategies
• Representing in appeals/petitions before the Commissioner of Income Tax (Appeals) and the Income Tax Appellate Tribunal, Central Board of Direct Taxes
• Coordination with legal counsel for high courts and the Supreme Court in complex tax litigation