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Taxation Services

International Taxation & DTAA

Cross-border tax structuring, transfer pricing, DTAA treaty benefits, and NRI taxation advisory.

Overview

Our international taxation practice helps businesses navigate the complexities of cross-border tax structures, transfer pricing regulations, and Double Taxation Avoidance Agreements (DTAAs). Whether you are an Indian company expanding overseas, a foreign entity entering India, or an NRI managing investments across borders, our team provides strategic advisory to minimize tax exposure while ensuring full compliance with tax laws in all relevant jurisdictions.

What We Cover

DTAA treaty analysis and benefit optimization
Transfer pricing documentation and compliance
Foreign tax credit computation and claims
Withholding tax advisory and compliance
NRI taxation and repatriation planning
PE (Permanent Establishment) risk assessment
BEPS compliance and country-by-country reporting
Cross-border M&A tax structuring

Our Process

1

Jurisdiction Analysis

Identify tax implications in both countries, understand domestic tax laws, and assess exposure across relevant jurisdictions.

2

Treaty Review

Analyze applicable DTAA provisions, identify eligible benefits like reduced withholding rates, and evaluate treaty override scenarios.

3

Structuring

Design compliant and tax-efficient structures considering holding company jurisdiction, financing arrangements, and IP ownership.

4

Documentation

Prepare transfer pricing reports, maintain contemporaneous documentation, and obtain necessary certificates (Form 15CA/CB, TRC).

5

Filing & Compliance

Ensure timely returns and disclosures including Form 3CEB, country-by-country reports, and foreign asset declarations.

6

Ongoing Support

Monitor regulatory changes across jurisdictions, handle tax notices, and provide advisory on evolving international tax landscape.

Frequently Asked Questions

A Double Taxation Avoidance Agreement (DTAA) is a tax treaty between two countries that prevents the same income from being taxed twice. It provides reduced withholding tax rates, exemptions for certain income types, and mechanisms for foreign tax credit claims.

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