India · Service
DTAA optimisation, withholding tax, PE exposure and inbound and outbound structuring — engineered by partners who litigate the positions they advise.
Cross-border transactions fail when tax is treated as an afterthought. We structure inbound investment, outbound remittances and global income flows so that treaty relief is defensible, withholding is correct at source, and permanent-establishment exposure is controlled before it crystallises into a dispute.
Eligibility analysis, tax-residency certificates, Form 10F and beneficial-ownership positioning to secure the lower treaty rate.
Correct characterisation of payments, rate determination and lower-deduction certificates for foreign remittances.
Chartered-accountant certification and filing for every foreign remittance, with defensible backup.
PE-risk mapping for fixed-place, agency and service PE, with attribution and mitigation strategy.
Holding-company location, repatriation routes and entity choice optimised for treaty and FEMA outcomes.
FTC computation and Form 67 filing so that tax paid abroad is not lost in India.
We map every cross-border flow, counterparty and treaty in play.
We design the holding, contracting and remittance structure for the lowest defensible tax.
We certify remittances, file forms and obtain certificates in real time.
We maintain documentation that survives scrutiny and represent you if questioned.
We advise the position we are willing to defend — not the one that is easy to file.
Client identities withheld for confidentiality; outcomes described in general terms.
Multiple foreign-currency remittances re-characterised and certified under the applicable DTAA, with withholding reduced to the treaty rate.
Withholding cut to treaty rate, fully certifiedService and agency arrangements restructured to remove permanent-establishment risk before assessment.
PE risk closed pre-assessmentBook a confidential consultation with a partner to map your treaty, withholding and PE exposure before your next remittance.
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