Tax & Fund Flow Optimisation

India inside a global group means transfer pricing, withholding and treaty positions — built to hold up, not just to file.

Schedule of work

  • Transfer pricing structures — planning, benchmarking, 3-tier documentationRelated-party pricing that reads true.
  • Withholding tax advisory & lower-withholding certificates (Form 13/15E)Fixing the withholding cash-flow drain.
  • International tax evaluation — DTAA positions, PE analysisTreaty positions and PE risk, assessed.
  • Profit & cash repatriation planningGetting profits out efficiently.
  • Advance Pricing Agreements & Safe HarbourCertainty on pricing, agreed in advance.
  • GST advisoryGST positions across the group.
  • GST noticesIT and GST notices, answered properly.

How we work

  1. Map the structureWhere India sits in the group, and where tax leaks and exposures live.
  2. Set the positionsTP structure, withholding, treaty and repatriation positions — documented to hold.
  3. DefendAudits, APAs and representation when a position is tested.

Handled by

Transfer Pricing & International Tax

New Delhi · Est. 2026

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Management Challenges We've Seen Before

Real situations. Real stakes. Real outcomes.

The refund was ready to file. But the timing wasn’t right.Growing an Indian business · GSTRead the story The subsidiary was making losses. The tax authorities would want to know why.Expanding into India · Transfer PricingRead the story A tax clarification increased project profitability.Growing an Indian business · GSTRead the story

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