International taxation is the study or determination of tax incidence on a person or business on cross border economic transactions subject to taxation laws of different countries. Governments usually limit the scope of their income taxation in some manner territorially or provide for offsets to taxation relating to extraterritorial income. The countries around the globe follow residence-based taxation rule and source-based taxation rule. Under residence-based taxation rule, a country levies tax on the worldwide income of its resident or citizen and under source-based taxation rule, a country levies tax on the income that originates from the source, which is present in that country namely a business activity, a capital asset etc.
Following advisory services may be provided in the area of International Taxation:-
- Obtaining statutory tax registrations such as Permanent Account Number (PAN), Tax Deduction and Collection Number (TAN) for foreign companies/ their project office (PO), liaison office (LO) or branch office (BO) in India.
- Advisory on Permanent Establishment (PE) exposure and corresponding tax impact
- Advisory on WHT implications on payments to non-residents and evaluation of tax treaties for availability of tax relief
- Advice on domestic, international and cross-border transactions.
- Assistance with reviewing agreements between related parties from a transfer pricing perspective.
- Assist in filing tax returns.
- Assist in preparing and filing appeals.
- Representation with the tax authorities.
- Advice on aspects of foreign exchange law.
- Advice and assistance in connection with acquisition, restructuring, mergers & direct and indirect tax due diligence.
- Tax consultancy on social security matters for employers moving abroad.
- Assistance with Country-By-Country Reporting (“CbCR”) requirements.
- Advising in respect of transfer pricing documentation based on the OECD Guidelines.
- Evaluation of claim of foreign tax credits and assistance in claim of tax refund from overseas authorities under international tax advisory services.
- Advisory on availability/applicability of tax benefits under trade agreements.
