Planning.
Cross-border tax planning for non-residents and Indian groups with foreign operations.
About this service.
Non-residents earning India-source income, Indian groups with foreign subsidiaries, expatriates and foreign investors.
International tax planning addresses the cross-border tax issues that arise for foreign entities investing in India, Indian entities investing abroad, and individuals with cross-border income or residency questions.
The firm advises on Double Tax Avoidance Agreement (DTAA) benefits, Permanent Establishment (PE) exposure, Place of Effective Management (POEM), and tax-residency-certificate matters — before arrangements are put in place.
Planning is aligned to the arm's-length principle and to India's treaty network, with attention to BEPS-driven developments.
What the engagement covers.
DTAA application and treaty-benefit advisory
Permanent Establishment and tax-presence planning
POEM analysis for foreign entities
Equalisation Levy and Significant Economic Presence advisory
Residency and tax-residency-certificate advisory
Inbound / outbound investment planning
Applicable laws and standards.
Other tax services.
Top questions.
The questions clients most often ask about this service. For anything specific to your situation, write to the firm.
Planning cross-border tax positions for non-residents investing in India and Indian groups with foreign operations.
A Double Tax Avoidance Agreement (tax treaty) that allocates taxing rights between countries and relieves double taxation.
A taxable presence that can arise from cross-border activity; planning helps manage this exposure.
Place of Effective Management — used to determine the tax residency of a foreign company.
A certificate of residence often required to claim treaty benefits, subject to the treaty's conditions.
It may apply to certain digital transactions; the firm assesses applicability to your facts.
Non-residents with India-source income, Indian groups with foreign subsidiaries, and expatriates.
No. Conditions — including anti-abuse and principal-purpose tests — must be satisfied and documented.
Yes. Both inbound investment into India and outbound investment abroad are covered.
Positions are aligned with BEPS-driven developments, including substance and documentation requirements.
Looking for planning support?
Write to the firm to discuss the engagement. Each engagement is scoped through a formal letter, preceded by independence and conflict-of-interest checks.