Advisory Service

Not a generic firm — the full India tax stack.

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

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DTAA countries covered
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Companies advised
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Years experience
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Service areas
Withholding Rates — What Applies
Domestic Law Rates
Dividends — 20%Royalty / FTS — 10%Interest — 20%
Under DTAA (Typical)
Dividends — 0–15%Royalty / FTS — 10%Interest — 10–15%
Risk Exposure
PE tax — 40%TP penalty — up to 300%

Our Services

International tax services for foreign companies in India.

DTAA Planning

Core Service
Eligibility, TRC & withholding optimisation

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

DTAA eligibility assessmentTRC advicePrincipal Purpose TestWithholding optimisation

Transfer Pricing

Core Service
Model design, benchmarking & Form 3CEB

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.

Pricing model designMSA draftingBenchmarking studyForm 3CEB + APA

Withholding Tax

TDS analysis, Form 27Q, 15CA/15CB

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.

Domestic vs DTAA ratesForm 27Q filingSection 197 certificatesForm 15CA/15CB

PE Risk Management

Agency PE, Service PE & safeguards

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 assessmentAgency & Service PEManagement planOperational safeguards

FEMA Compliance

FCGPR, FLA return, ECB structuring

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

FCGPR filingAnnual FLA returnForm 15CA/15CBECB structuring

Cross-border Restructuring

LO/Branch conversion, IP migration, M&A

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 to subsidiaryIP migrationM&A due diligenceExit planning
Detailed Guides

Go deeper on any topic

Transfer pricing in India
Transfer pricing in India
Complete guide to TP compliance
Read guide →
FDI rules & FEMA compliance
FDI rules & FEMA compliance
Sector limits, filings & penalties
Read guide →
Foreign company registration
Foreign company registration
Branch, LO, or subsidiary in India
Read guide →

Withholding Rates

India DTAA withholding rates.

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

DTAA Quick Reference
Key treaty countries — indicative withholding rates
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%
India (domestic law)
Dividends
20%
Royalties
10%
FTS
10%
Interest
20%
United States
Dividends
15–25%
Royalties
10–15%
FTS
10–15%
Interest
10–15%
United Kingdom
Dividends
15%
Royalties
10–15%
FTS
10%
Interest
10–15%
UAE
Dividends
10%
Royalties
10%
FTS
Nil–10%
Interest
Nil–12.5%
Singapore
Dividends
10–15%
Royalties
10%
FTS
10%
Interest
10–15%
Australia
Dividends
15%
Royalties
10–15%
FTS
10–15%
Interest
15%
Germany
Dividends
10–15%
Royalties
10%
FTS
10%
Interest
10%
Japan
Dividends
10%
Royalties
10%
FTS
10%
Interest
10%

Note: Rates shown are indicative. Actual rates depend on shareholding %, nature of income, beneficial ownership, and the Principal Purpose Test. Contact us for a precise analysis.

Need expert international tax advice for your Indian operations?

DTAA planning, transfer pricing benchmarking, and withholding tax optimization by Ex-Big 4 CA team.

Arya — India Entry Advisor
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