Comprehensive Tax & Transaction Advisory

Corporate tax touches nearly every major business decision — from routine compliance to how a transaction or restructuring is eventually taxed. With frequent changes in law and closer scrutiny from tax authorities, businesses need advisors who combine compliance discipline with forward-looking planning. We help businesses meet their corporate tax obligations while identifying opportunities to improve efficiency and manage risk. Our services include:

• Managing the preparation and filing of corporate income tax returns and statutory disclosures.
• Reviewing operational expenditure to validate and maximise eligible tax incentives, deductions and allowances.
• Conducting health checks to identify compliance gaps, mitigate risks and strengthen internal tax processes.
• Securing regulatory approvals, advance rulings and lower withholding tax certificates.
• Conducting multi-jurisdictional tax impact assessments for complex business transactions.
• Formulating tax minimisation strategies through business model transformation and corporate reorganisation.
• Designing tax-efficient domestic and cross-border fund repatriation frameworks.

As businesses grow across borders, their tax exposure grows with them — spanning treaty positions, withholding obligations, permanent establishment risk and cross-border structuring. We advise businesses on structuring cross-border operations and transactions to manage this exposure and stay compliant with evolving international tax rules, including BEPS and MLI developments. Our services include:

• Structuring inbound and outbound investment flows for tax efficiency.
• Reviewing cross-border commercial agreements to identify and mitigate tax exposure.
• Advising on Tax Deduction at Source (TDS) under domestic law and tax treaties.
• Assessing Place of Effective Management risk to safeguard foreign entity status.
• Identifying and mitigating Permanent Establishment risk (fixed, agency or service PE).
• Structuring international holding companies for asset protection and tax efficiency.
• Designing tax-efficient mechanisms for dividends, buybacks, interest and royalties.
• Structuring executive compensation for cross-border assignees.
• Managing tax residency transitions to prevent unintended global income exposure.

For multinational groups, transfer pricing is one of the most closely scrutinised areas of tax compliance — policies need to be commercially sound as well as defensible before tax authorities. We help businesses design, document and defend transfer pricing policies that reflect their commercial and operational reality. Our services include:

• Reviewing transfer pricing requirements across jurisdictions and advising on appropriate transaction structures.
• Preparing transfer pricing documentation, benchmarking studies, functional and risk analyses, and CbCR / Master File filings.
• Reviewing transfer pricing policies against the group's business model, commercial objectives and value creation.
• Assessing the tax impact of procurement, logistics, intercompany services and distribution arrangements.
• Supporting APA applications, safe harbour arrangements and related compliance and monitoring.
• Representing clients during transfer pricing assessments, audits and proceedings, including preparation of submissions and responses.

Goods and Services Tax (GST) is India's comprehensive indirect tax regime for the supply of goods and services. Since its introduction, GST has transformed the indirect tax landscape by consolidating multiple taxes into a unified framework. Given the complexity of GST legislation, frequent regulatory developments and sector-specific requirements, businesses need a structured approach to stay compliant while managing tax risks and opportunities.

We provide end-to-end GST advisory and compliance support across the GST lifecycle — helping clients navigate complex provisions, structure transactions efficiently, maintain compliance and address exposures proactively. Our services include:

• Advising on transaction and business structures to improve tax efficiency while ensuring GST compliance.
• Providing end-to-end guidance on GST law and its impact on business operations and transactions.
• Advising on place and time of supply, valuation, input tax credit, exemptions and industry-specific GST matters.
• Supporting the preparation and filing of monthly, quarterly and annual GST returns.
• Reconciling GSTR-2B with books of account and vendor records to identify and resolve mismatches.
• Preparing and filing GSTR-9 and GSTR-9C, including related reconciliations.
• Supporting refund applications relating to exports, inverted duty structures, excess cash balances and other eligible claims.
• Providing end-to-end support during GST audits and assessments across India.
• Drafting and filing responses to GST notices and assisting through the conclusion of proceedings.
• Representing clients before GST authorities and resolving matters arising during audits, assessments and proceedings.

M&A and strategic transactions play a key role in driving growth, unlocking value and creating business synergies. We bring extensive experience in transaction structuring to help clients navigate complex deals with a commercial, practical approach.

Our support spans the transaction lifecycle — from structuring and negotiations to documentation and post-deal matters — integrating tax, regulatory and business considerations to achieve efficient outcomes and maximise value. Our services include:

• Conducting due diligence — reviewing financial, tax, legal and commercial aspects of a target to identify risks, exposures and value drivers.
• Highlighting critical findings and actionable insights to support deal structuring, negotiations and decision-making.
• Advising on acquisitions and divestments involving shares, assets, business transfers, slump sales, mergers and demergers, including buybacks, capital reduction and delisting.
• Supporting corporate reorganisations such as inter-company mergers, demergers, capital restructuring and initiatives to improve balance sheet efficiency.
• Assisting from initial scheme preparation through execution, coordinating with valuers, legal counsel, auditors and other stakeholders, and preparing transaction documentation.
• Structuring transactions for tax efficiency and, where feasible, tax-neutral outcomes, while ensuring compliance with applicable requirements.

GIFT IFSC, located within GIFT City in Gandhinagar, Gujarat, is developing into a significant hub for international financial and cross-border activity. Its fiscal incentives, modern infrastructure and dedicated regulatory framework offer financial services businesses an attractive platform for establishing and expanding their international operations.

Our services cover setting up entities and operations within GIFT IFSC, as well as structuring inbound and outbound fundraising and investment activity. We support clients through regulatory engagement and implementation, with the goal of building commercially viable, tax-efficient and compliant structures that make the most of the GIFT IFSC ecosystem. Our services include:

• Evaluating eligibility to establish a presence or undertake fundraising and investment activity within GIFT IFSC.
• Advising on applicable regulatory requirements and available tax incentives.
• Managing end-to-end application preparation and representing clients before the IFSCA.
• Designing and structuring the proposed setup or transaction for tax, legal and operational efficiency.
• Supporting the complete execution process through to establishment or completion of the transaction.
• Providing ongoing tax and regulatory guidance to support compliant, efficient day-to-day operations.

As businesses expand across markets and family interests become increasingly international, managing ownership, wealth and succession grows more complex. We help families build practical ownership and succession frameworks designed to preserve wealth, support long-term growth and enable a smooth transition across generations — tailored to each family's needs, including situations spanning multiple jurisdictions.

• Assisting with drafting trust deeds, wills and family charter documents.
• Reviewing investment holding structures for promoter families from a tax and regulatory perspective.
• Advising on the tax treatment of sale of assets and shareholdings.
• Advising on residency planning from a tax and FEMA perspective.
• Advising on repatriation of capital through available routes (such as LRS, NRO/NRE, OPI).
• Creating onshore and offshore family trust structures and efficient settlement of assets.
• Assisting with approvals from regulatory authorities (such as RBI, SEBI, NCLT).

Whether it's a global business establishing a footprint in India, or an Indian business expanding overseas, getting the structure right from the outset shapes tax efficiency, compliance and long-term flexibility. We support clients on both sides of the border — inbound and outbound — from choosing the right structure through to getting operations up and running.

Inbound — Setting Up in India

• India Entry & Investment Structuring — advising on the right Indian business vehicle, investment structure, funding requirements and a tax-conscious investment approach.
• Entity Formation & Regulatory Setup — end-to-end assistance with establishing the Indian entity, preparing constitutional and incorporation documents, appointing directors, and completing registrations and licences.
• Funding & Banking Assistance — support in bringing in initial capital, structuring subsequent investments, setting up banking arrangements, and meeting FEMA and foreign exchange requirements.
• Finance & Compliance Infrastructure — setting up systems and processes for bookkeeping, financial reporting, payroll, taxation, corporate secretarial matters and routine statutory obligations.
• Tax & Regulatory Compliance — ongoing advisory and compliance support covering income tax, GST and other indirect taxes, transfer pricing, corporate law, FEMA and related requirements.
• Cross-Border Transactions & Repatriation — advising on international payments, receipt of funds, dividend and other repatriation mechanisms, and structuring cross-border transactions.

Outbound — Expanding Overseas

• Outbound Investment Structuring — advising on the appropriate overseas jurisdiction, holding structure and investment route (including ODI and OPI) for expanding abroad.
• Entity Setup Support — coordinating incorporation, registrations and licensing in the target jurisdiction, working alongside local advisors and counsel.
• FEMA & Regulatory Compliance — advising on RBI/FEMA approvals, reporting requirements and compliance for outbound investments and overseas subsidiaries.
• Funding Structuring — structuring funding for overseas subsidiaries and joint ventures through equity, debt or hybrid instruments.
• Tax-Efficient Global Structuring — designing holding structures to manage global tax exposure, repatriation and treaty benefits.
• Ongoing Compliance Support — supporting annual filings and FEMA reporting (such as APR and FLA), and coordinating with overseas advisors.

Beyond initial set-up, we support businesses on both sides as they grow:

• Growth, Reorganisation & Transactions — supporting scale-up, business reorganisations, mergers, acquisitions and strategic transactions, including regulatory clearances.
• Dispute Resolution & Tax Representation — support in tax and regulatory matters including advance pricing arrangements, advance rulings, assessments, appeals and litigation.