Advisory Service

International Tax
Advisory for India

DTAA structuring, transfer pricing, withholding tax, FEMA compliance, and PE risk management — designed before your India entity opens its doors.

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Ex-KPMG Led Team
18+ years — India incorporations
📜
CA, CS & Accountants
Full multidisciplinary team
🌍
100+ Companies
Including foreign companies

Book a Tax Consultation

CA, CS & accountant team. Response within 24 hours.

After the call you receive
✓Tax structure memo — Your DTAA position, PE risk & WHT rates documented
✓TP guidance — Recommended pricing methodology for your model
✓Action list — Exact next steps with owner and timeline
Our Services

International tax services for
foreign companies in India

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DTAA Planning

Core Service

India has DTAAs with 90+ countries. Applied correctly, DTAA reduces withholding tax on dividends from 20% to 0–15%, and on royalties from 10% to 10% or below. We ensure the correct rate is applied to every cross-border payment.

› DTAA eligibility assessment
› Tax Residency Certificate (TRC) advice
› Principal Purpose Test (BEPS Action 6)
› Withholding tax optimisation
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Transfer Pricing

Core Service

India's TP enforcement is among the world's most aggressive. All intercompany transactions must be at arm's length, documented annually. We design the TP model before incorporation and maintain it every year.

› Intercompany pricing model design
› MSA and agreement drafting
› Annual benchmarking study
› Form 3CEB filing + APA advisory
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Withholding Tax

Every payment from India to a foreign company is subject to TDS. DTAA rates are often significantly lower than domestic law. We ensure the correct rate is applied and all TDS returns are filed.

› TDS rate analysis — domestic vs DTAA
› Form 27Q quarterly returns
› Section 197 lower TDS certificates
› Form 15CA/15CB for all payments
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PE Risk Management

A PE triggers 40% tax on the parent's India-attributable profits. PE risk is subtle and often missed — until the audit notice arrives. We assess and manage PE risk from day one.

› PE risk assessment
› Agency PE and Service PE analysis
› PE management plan
› Operational safeguards
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FEMA Compliance

FEMA violations attract penalties up to 3× the transaction value. We manage all FEMA filings as part of every ongoing engagement — FCGPR, FCTRS, FLA, ECB, and compounding.

› FCGPR within 30 days of FDI
› Annual FLA return — 15 July
› Form 15CA/15CB for foreign payments
› ECB structuring and reporting
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Cross-border Restructuring

Converting a liaison office to a subsidiary, moving IP, consolidating group entities — cross-border restructuring in India triggers multiple tax events that must be planned carefully.

› LO/Branch to subsidiary conversion
› IP migration tax planning
› M&A due diligence — India tax
› Exit planning and winding up
Detailed Guides
DTAA Quick Reference

India DTAA withholding rates —
key treaty countries

India's domestic rates: 20% dividends, 10% royalties, 10% FTS, 20% interest. DTAA rates are almost always lower — often significantly.

Country
Dividends
Royalties
FTS
Interest
🇮🇳 India (domestic law)
20%
10%
10%
20%
🇺🇸 United States
15–25%
10–15%
10–15%
10–15%
🇬🇧 United Kingdom
15%
10–15%
10%
10–15%
🇦🇪 UAE
10%
10%
Nil–10%
Nil–12.5%
🇸🇬 Singapore
10–15%
10%
10%
10–15%
🇦🇺 Australia
15%
10–15%
10–15%
15%
🇩🇪 Germany
10–15%
10%
10%
10%
🇯🇵 Japan
10%
10%
10%
10%
Important: Rates shown are indicative. Actual rates depend on shareholding %, nature of income, beneficial ownership, and Principal Purpose Test. Contact us for a precise analysis for your specific transaction.

Ready to get your India tax structure right?

Book a free 30-minute consultation. We'll review your structure, identify key risks and savings, and give you a clear action plan.