Our International tax practice  includes Advising and representation on a variety of complex Cross-border and Domestic transactions encompassing areas such as:

Another major branch of international taxation is Transfer Pricing. India  introduced transfer pricing regime more than a decade ago and has since then Transfer Pricing has been the single most important anti avoidance tool applied by the tax department since India had not introduced any other significant anti avoidance measures till 2012. This has led to unimaginable tax disputes between the taxpayers and the revenue. Every time an issue settles the dust, new one crops up making it difficult for foreign and Indian taxpayers to do business in India with certainty. The transfer pricing regime that India has adopted is by and large similar to the US and OECD models with some modifications to prevent its base erosion. To avoid multiplicity of disputes, an attempt was made to specifically address non-resident investors by introducing Dispute Resolution Panel (DRP). This led to a time saving mechanism to decide the disputes expediently. However, the functioning and the remedy provided by the DRP did not prevent the proliferating disputes. Therefore, the Government of India  introduced the Advance Pricing Agreement (APA) scheme in 2012 which is similar to other countries to reduce transfer pricing disputes and boost investors’ confidence. The success rate and the credibility of the parties to APAs have to be time tested.