Advisory · Tax Advisory & International Tax

Your India tax position,
aligned across borders.

Tax advisory and international tax cover your India entity's corporate tax position and its cross-border exposure — applying the right Double Taxation Avoidance Agreement (DTAA) so income isn't taxed twice, withholding the correct rate on royalties, fees, interest, and dividends, managing permanent-establishment risk, and repatriating profits tax-efficiently. Planned year-round, not just filed.

For a foreign-owned India entity, the expensive tax mistakes are cross-border: double taxation, wrong withholding, and an accidental permanent establishment. We set the treaty, withholding, and structuring position before transactions happen, file it correctly, and defend it if it's challenged.

Cross-Border Tax
Live
Tax positionTreaty-efficient
Map
Plan
TRC
File
Defend
Tax status
  • DTAA reliefApplied
  • Withholding (146)Certified
  • PE riskManaged
No double tax
DTAA relief
Correct WHT
145 / 146
DTAA relief
No double taxation
Withholding
Correct rates, on time
PE risk
Managed before it bites
Where cross-border tax bites

Cross-border tax is where India quietly costs you.

  • Double taxation

    Are you being taxed twice on the same income?

    Without applying the right Double Taxation Avoidance Agreement, profits, royalties, and fees can be taxed in India and again at home. The relief exists — but only if you claim it correctly.

  • Withholding

    Is the right tax being withheld on cross-border payments?

    Payments to and from India — royalties, interest, fees, dividends — carry withholding tax at rates set by law or the treaty. Get it wrong and you over-pay, or face disallowance and penalties.

  • Permanent establishment

    Could your activity create a taxable presence in India?

    A dependent agent, a fixed place, or the wrong contracting model can create a permanent establishment — and an India tax bill on profits you didn't expect to be taxed here.

  • Planning gap

    Is anyone planning your India tax, or just filing it?

    Year-round planning sets the entity, treaty, and withholding position before transactions happen. Filing after the fact locks in whatever exposure was already created.

Domestic compliance is the visible part of India tax. The costly part is cross-border: relief you didn't claim, withholding you got wrong, a presence you didn't realise was taxable, and a return filed with no plan behind it. All of it is manageable when it's planned ahead of the transaction.

What's included

Tax advisory that crosses borders cleanly.

Corporate tax

Corporate tax advisory & planning

Year-round advice on your India entity's corporate tax position — structure, deductions, incentives, and timing — so the return is the outcome of a plan, not a surprise.

  • Tax-position planning
  • Deductions & incentives
  • Return preparation & filing
Treaty / DTAA

DTAA & treaty relief

We apply the relevant Double Taxation Avoidance Agreement so income isn't taxed twice — securing treaty rates, tax residency certificates, and the correct relief mechanism.

  • Treaty rate analysis
  • Tax residency certificate (TRC)
  • Foreign tax credit / relief
Withholding

Withholding tax (TDS) on cross-border flows

We determine the correct withholding on royalties, fees, interest, and dividends moving in and out of India, prepare the filings, and issue the certifications banks require.

  • Section 393 withholding analysis
  • Form 145 / 146 certification
  • Treaty-rate application
PE & structure

Permanent establishment & structuring

We assess and manage permanent-establishment risk and design the contracting and operating model so your India presence is taxed the way you intend.

  • PE risk assessment
  • Contracting model review
  • Attribution & mitigation
Repatriation

Profit repatriation & treaty efficiency

Dividends, royalties, and service fees structured to move profits home tax-efficiently and in line with both FEMA and the applicable treaty.

  • Dividend & royalty planning
  • Treaty-efficient routing
  • FEMA-aligned flows
Controversy

Notices, assessments & representation

When the tax department raises a query or assessment, we respond, represent your position, and pursue treaty relief or appeal to resolve it.

  • Notice & assessment response
  • Representation before authorities
  • MAP / appeal where needed
How we work

From exposure to a planned position.

01Review
Map your tax footprint

We review your India entity, group structure, and cross-border flows to find where double tax, withholding, and PE exposure sit.

Your full tax exposure mapped
02Plan
Set the position

We design the treaty, withholding, and structuring position — securing TRCs and treaty rates and closing PE risk before transactions happen.

A planned, treaty-efficient position
03Comply
File and certify

We prepare the corporate-tax return, withholding filings, and the Form 145/146 certifications, on time and consistent with the plan.

Filed and certified correctly
04Defend
Stand behind it

We monitor for notices and assessments and represent your position, pursuing DTAA relief or appeal whenever it's challenged.

A position that holds up
FAQ

India & international tax, answered.

What is a DTAA and how does it help my India business?

A Double Taxation Avoidance Agreement (DTAA) is a treaty between India and another country that prevents the same income from being taxed in both. It does this by allocating taxing rights, capping withholding-tax rates on cross-border payments (like royalties, interest, and fees), and providing relief — usually a tax credit or exemption — for tax already paid in the other country. For a foreign-owned India entity, applying the right DTAA correctly is what stops profits, royalties, and service fees from being taxed twice. Claiming it requires a tax residency certificate and the correct filings.

What is withholding tax (TDS) on payments to and from India?

India requires tax to be deducted at source on many cross-border payments — royalties, technical and professional fees, interest, and dividends. The rate is the lower of the rate under Indian law or the applicable DTAA, and remittances generally require a chartered accountant's certificate in Form 146 and a Form 145 filing. Getting the rate and certification right avoids both over-withholding (which strands cash) and under-withholding (which triggers disallowance, interest, and penalties).

What is permanent establishment (PE) risk and why does it matter?

A permanent establishment is a taxable presence that a foreign company can create in India — through a fixed place of business, a dependent agent who habitually concludes contracts, or certain service arrangements. If you create a PE, India can tax the profits attributable to it, often unexpectedly. Managing PE risk means structuring your contracting model, personnel, and activities so your India presence is taxed the way you intend, not the way an assessment officer reconstructs it after the fact.

What's the difference between tax advisory and just filing my tax return?

Filing is compliance — reporting what already happened. Tax advisory is planning: setting the entity structure, treaty position, withholding approach, and transaction timing before the year unfolds, so the return reflects a deliberately efficient and defensible position. For cross-border businesses the gap is large, because most international-tax exposure (double taxation, wrong withholding, PE) is created by decisions made long before the return is due.

How do I repatriate profits from India tax-efficiently?

Profits typically move home as dividends, royalties, or service fees, and each has a different tax and treaty treatment plus FEMA conditions. The efficient route depends on your structure and the applicable DTAA — for example, treaty-capped withholding on dividends versus the deductibility and withholding profile of royalties or fees. We plan the mix and timing so repatriation is both treaty-efficient and FEMA-compliant, rather than defaulting to whatever's simplest.

Do you handle Indian tax notices and assessments for foreign-owned companies?

Yes. We respond to queries, scrutiny notices, and assessments from the Indian tax department, represent your position before the authorities, and where double taxation arises we pursue relief through the DTAA's Mutual Agreement Procedure or the appellate route. Because we set the underlying position with documentation in mind, defending it is far more straightforward.

Book a free consultation

Plan your India tax before it plans you.

Tell us about your India entity and your cross-border flows. We'll map the exposure, set a treaty-efficient position, and handle the filings and certifications that come with it.

DTAA relief claimed correctly — no income taxed twice
Correct withholding on every cross-border payment, with 145/146 handled
Permanent-establishment risk assessed and structured around
Profits repatriated tax-efficiently and in line with FEMA
One in-house team planning, filing, and defending the position
Talk to our tax team
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