International Taxation

BSJ & Associates - International Taxation

For companies with presence in India as well as overseas, or for companies from other countries looking to set up presence in India, the concept of international tax and its implications need to be understand.

Where companies wishing to globalize their operations should have sound strategy for international taxation and international tax planning. It is  important to understand the concept of transfer pricing (TP). Transfer pricing is also one of the most critical tax aspects for international companies operating in India.

  • Planning and implementation of international tax and transfer pricing strategies.
  • Tax advisory on complex tax issue of cross-border transaction.
  • Advisory on withholding taxes and equalization levy.
  • Analysis and advisory with respect to permanent establishments of foreign companies/entities in India.
  • International tax services and advisory on aspects related to GAAR (General Anti-Avoidance Rules), DTAA (Double Taxation Avoidance Agreements).
  • Profit and cash repatriation planning for foreign establishments.
  • Transfer pricing advisory on complex structures and international transactions.
  • Representation before tax and transfer pricing authorities for tax assessments or audits by revenue authorities.

As multinationals across the world look to invest or establish themselves in India and begin to transact more actively, it is important that India’s tax and regulatory policies are well understood for enhancing growth and success opportunities.

Transfer pricing is the setting of the price for goods and services sold between controlled (or related) legal entities within an enterprise. In principle a transfer price should match either what the seller would charge an independent, arm’s length customer, or what the buyer would pay an independent, arm’s length supplier. While unrealistic transfer prices do not affect the overall enterprise directly, they become a concern when they are misused to lower profits in a division of an enterprise that is located in a country that levies high taxes and raise profits in a country that is a tax haven which levies no or low taxes.

BSJ has dedicated tax professionals with in-depth technical knowledge and practical experience, who the client can trust in relation to corporate tax and regulatory matters. The team provides advice on various tax matters and helps clients manage the complexities of multiple tax systems and cross-border challenges.

Our Transfer Pricing Documentation related services includes

Understanding the overall business environment and processes of the Group

Review and analysis of investment holding structure and entity wise functions conducted

Review and analysis of global outlook on the industry in which the Group is involved

Identification of relevant transactions for the purpose of section 92E of the Income Tax Act, 1961

Analysis of functions / activities that each of the entities involved

Analysis of transactions that are proposed to be compared with respect to the assets employed

Analysis of effective risk assumed by the entities during the course of the transaction

 Analysis from an economic perspective to evaluate on the method of computation of arms-length price for the transactions identified

Finalization of the method of computation of arm’s length price based on Rule 10B of the Income Tax Rule 1962 and OECD Transfer Pricing Guidelines

Searching the relevant databases for comparable data

Discussion and finalization of the comparable data from the universe identified

Review and discussion on various adjustments required for arriving at the final arm’s length price computation

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