Tax that follows the transaction.

We advise on the income-tax consequences of cross-border transactions for both inbound and outbound clients. The work covers residency analysis, characterisation of income under the Income Tax Act, 2025 and the relevant Double Taxation Avoidance Agreement, permanent-establishment analysis, withholding-tax compliance, transfer pricing and the procedural compliances that sit alongside (Form 15CA, 15CB, Form 67, Form 3CEB).

Cross-border tax is rarely a standalone question. We sequence the analysis: identify the transaction, identify the relevant section of the Income Tax Act, 2025, identify the relevant DTAA Article, identify the procedural compliance, then write a memo the promoter's CFO can act on. Where the question affects audit or FEMA at the same time, the same team handles all three so that the answers do not contradict each other.

• Advisory on the taxation of non-residents in India, including DTAA analysis, beneficial-ownership tests and treaty entitlement.
• Withholding-tax determination, Form 15CA and Form 15CB certification on outward remittances.
• Permanent establishment risk analysis and structuring.
• Transfer pricing study, contemporaneous documentation, Form 3CEB filing and CbC / Master File reporting where applicable.
• Foreign tax credit claims under sections 90 / 91 and Form 67 filing.
• Advisory on Equalisation Levy, Significant Economic Presence and the digital-economy provisions.
• Representation in scrutiny and appellate proceedings on cross-border issues.