Tax

We are one of the few law firms in India that has full-service tax capabilities and offers end-to-end advice on matters ranging from establishment of entities in India to the minutest of operational issues. We advise on offshore tax matters, tax structuring, use of tax treaties to invest in India, transfer pricing, and other local tax issues (including withholding taxes, capital gains tax, permanent establishment, employee benefits, and tax holiday schemes).

Recent Transactions

  • ARM LLC, USA, on Indian tax withholding advice with respect to its UAE joint venture being contemplated with an Indian entity with which ARM LLC already had an existing joint venture.
  • Aims Impex Private Limited on tax structuring in a M&A deal involving sale of an Indian chemical manufacturing business to another Indian strategic buyer.
  • Pillsbury LLP on certain offshore transaction structure alternatives and the Indian tax consequences relating to capital gains tax, corporate tax and stamp duty issues, indirect transfer tax provisions, and their interplay with the general anti avoidance rules.
  • McGill USA on Indian tax issues in relation to the transfer of shares of an Indian company from a non-resident to another non-resident, valuation requirements as per the Indian tax rules, calculation of capital gains tax liability and tax withholding requirements, and whether gifting of the shares could be a workable option.
  • Bär & Karrer AG, Switzerland, on the treatment of shares, options, dividend pay outs or cash to be allocated to the client’s Indian subsidiary employees; applicability of social security taxes; valuation requirements; and payroll obligations in the process of adopting an equity participation plan for its future Swiss and Indian subsidiary employees.
  • NapCloud, USA, on tax issues and transfer pricing.
  • Zephyr Software Holdings, USA, on a complex offshore tax restructuring transaction.
  • Gibtele on permanent establishment and employee tax issues in relation to employment of Indian residents through a professional employer organization in India.
  • Govecs Group, Germany, on tax structuring, permanent establishment risks and other issues for the Indian entity regarding their proposed activities in India.
  • DyStar Holding Pte Limited, Singapore, on royalty fee withholding tax and penalties on account of non-payment.
  • Linode LLC, USA, on tax and transfer pricing issues, as also on the Advance Pricing Agreement (APA) regime. 
  • Sysdig, Inc. on permanent establishment and employee tax issues. 
  • Builder Homesite, Inc. on tax structuring, intermediate holding company structures and transfer pricing issues in relation to acquisition of Indian entities.
  • Baidu (Hong Kong) Limited on tax issues in relation to the establishment of a subsidiary in India.
  • NantHealth Inc. on tax issues in relation to the sale of its Indian subsidiary to Allscripts Healthcare Solutions, Inc.
  • Grab Taxi Holdings Pte Ltd. on a proposed tri-partite joint venture arrangement with an Indian company and a foreign company.
  • United Retirement Plan Consultants, Inc. on their investment and tax structuring in India in relation to the proposed acquisition of MGA Consultants in Baltimore, Maryland, for cash and stock.
  • Hydrochem LLC, USA on the requirements of withholding tax certificate in relation to an agreement with an Indian company to provide certain services.
  • Nippon Soda Co. Limited on complex Indian tax and permanent establishment issues related to the launch of a business platform in India to promote its product sales.
  • Lumiata, Inc. on transfer pricing and permanent establishment issues in relation to its Indian subsidiary that was owned by one of the client’s US employees and an Indian resident, and the client wanted to transfer ownership of the Indian subsidiary from the employee and the Indian resident to itself.
  • Andreas Neocleous and Co LLC on a matter following major amendments to the India-Mauritius and India-Singapore tax treaties.
  • Tavistock Corporation (in conjunction with Tiger Woods Foundation) on Indian withholding tax issues in respect of sponsorship payments from India to the USA.
  • CPA Australia Limited in connection with tax and permanent establishment issues, and regulatory concerns on its proposal to appoint an agent in India to promote and market its activities in India.