Introduction
When the businesses are spread worldwide, it becomes essential to have guidance from experts about the tax laws which can impact the business.
As the business expand into other territories both the opportunities and risk multiply. One of the most dreaded risk faced by the business houses is of unknown taxation regime in the foreign territory that might take away all the commercial benefits. We help our clients to concentrate on the opportunities while we take care of the taxation risk. To take full benefit of tax opportunities and to avoid the pit falls it is essential that the business strategies is properly aligned to the tax jurisdictions overseas in which it is operating.
International Taxation : Services we offer
1. Comprehensive International Transactions Review (CITR)
An extensive review of International Transactions from the perspective of FEMA, Transfer Pricing, DTAA, and others.
2. Foreign Exchange Management
A complete check-up of the Company/Individual from perspective of Forex laws in India.
3. Transfer Pricing
Transfer Pricing Audit and assistance to ensure the alignment with Transfer pricing regulations and to mitigate risk.
4. NRI & Expatriate Services
Assistance in Planning, Compliance & Advisory to NRIs and Expatriates.
5. Business Strategies
Assistance on entry/exit strategies in and outside India & Business Structuring Services.
6. Tax Advisory Services
When the businesses are spread worldwide, it becomes essential to have guidance from experts about the domestic and international tax laws which can impact the business.
Comprehensive International Transactions Review (CITR)
About CITR
CITR is an extensive review of International Transactions from perspective of –
- Foreign Exchange Management Act, 1999 – It is an Act to manage and regulate transaction involving Foreign Exchange. Any transactions, be it investment in India or Investment outside India, be it export or an import, be it giving of guarantee to person outside India or investment by Foreign Institutional Investors fall under the purview of Foreign Exchange Management Act, 1999.
In “CITR” we follow balance sheet approach for doing the due diligence. We go through each balance sheet item and verify it vis a vis applicability of FEMA provision and compliance level thereof.
- Provisions of International Taxation as per Indian Income Tax Act, 1961 – Globalisation has reduced the world to a village. With the expansion of business in overseas territories both the opportunities and risks multiply. One of the aspects to be taken care of by the business houses is of unknown taxation regime in the foreign territory that might take away all the commercial benefits. Compliance has to be carried out simultaneously with the execution.
In “CITR” we verify tax positions and ascertain tax exposure, if any, review credit available/claimed, Income Tax Returns, agreements like cost sharing agreements etc.
- Transfer Pricing Regulations – In the globalised environment where business houses are becoming smart, the tax authorities are getting smarter with Indian transfer pricing regime importing global concepts like BEPS (Base Erosion and prof it shifting), thin capitalisation and secondary adjustments either taking birth or getting adopted. With the newer ways of doing business in global space it is essential that all the business strategies are aligned to proper and planned taxation policy. With ever increasing cross border transactions, it is essential that the Transfer pricing policies and solutions are tailored made to needs, uncomplicated, innovative, effective, forward-thinking, complaint and practical to implement.
In “CITR” we analyse appropriateness of documentation, method used, quality of comparables, status of assessments, deemed transactions, Form 3CEB inter alia.
- Expatriate Taxation – Moving to a foreign country often proves challenging. Coming to terms with a new tax system is one of the more significant factors contributing to this challenge. It is important to understand about changes to the personal income tax and implications on social security contributions as a result of such a move and to understand the steps that are advisable to be taken before leaving the home country both by the company as well as the employee. Taxation of Expatriate is a tricky affair not only for the employee but also for the employer.
In “CITR” we review all agreements/policies, ascertain the correct tax liability, determine maximum benefit of taxes paid, help avoid double taxation of Income along with review of benefits available under Social Security Agreement, if any.
- Double Taxation Avoidance Agreement – The DTAA is a treaty signed between countries for avoidance of double taxation on income.
In “CITR” we analyse every foreign exchange transaction undertaken and help our clients’ avail DTAA benefit, if not already availed.
- Other governing provisions – Foreign Trade Policy, Companies Act, 2013, Assessment & Arbitration, Trade Finance.
Why CITR?
In CITR, we diagnose the following:
- Compliance that are required to be done
- Exposure that a transaction may have
- Prudence that may or may not be there
- Structuring best suited to your business
- Benefits which you may not be availing