Cross-Border Advisory • Section 92 / DTAA / BEPS

International Taxation & Transfer Pricing Advisory

Strategic cross-border tax advisory, bilateral treaty interpretation (DTAA), transfer pricing documentation, and foreign investment structuring for multinational corporations, foreign enterprises, and domestic conglomerates.

Transfer Pricing & Form 3CEB

Comprehensive transfer pricing documentation under Section 92E of the Income Tax Act, Form 3CEB accountant certifications, benchmarking analysis, Local File, Master File, and Country-by-Country Reporting (CbCR).

DTAA Treaty & BEPS Multilateral Instrument

Interpretation of bilateral Double Taxation Avoidance Agreements (DTAA), application of OECD BEPS Multilateral Instrument (MLI) provisions, Principal Purpose Test (PPT), and Permanent Establishment (PE) exposure assessments.

Form 15CA / 15CB Foreign Remittances

Chartered Accountant certification in Form 15CB and electronic filing of Form 15CA for outbound cross-border remittances covering royalty, technical service fees (FTS), dividend repatriation, and management service charges.

Inbound / Outbound FDI & FEMA

Structuring foreign direct investment (Wholly Owned Subsidiary, Branch, Liaison Office), Overseas Direct Investment (ODI) under revised FEMA regulations, and compounding representations before the Reserve Bank of India.

Equalisation Levy & Digital Tax

Advisory on Significant Economic Presence (SEP), Equalisation Levy compliances on e-commerce operators, and digital service withholding tax requirements for cross-border software platforms.

Expatriate & Inpatriate Mobility

Cross-border executive taxation, shadow payroll modeling, secondment agreement structuring, Section 6 tax residency evaluations, and Foreign Tax Credit (FTC Form 67) filings.

International Tax Practice

Consult with Cross-Border Tax Partners

Partner-led assistance on cross-border transactions, transfer pricing audits, and bilateral treaty optimization.

Schedule Tax Consultation
ICAI Code of Ethics Pull-Model Statutory Notice Information presented strictly on an objective pull-model basis in compliance with the Chartered Accountants Act 1949 and ICAI Guidelines.