Taxation

Tax law is rarely static, and the most commercially successful businesses treat tax planning not as an annual compliance exercise but as an ongoing strategic priority. Whether you are a domestic startup navigating your first funding round, a multinational managing cross-border flows, or a business operating in an emerging regulatory environment, a clear and defensible tax position is foundational to sustainable growth. Our tax advisory practice covers the full spectrum of direct and indirect taxation, combining technical depth with commercial pragmatism to deliver strategies that are robust, implementable, and anticipatory of the direction of regulatory travel.

Effective tax planning begins with understanding the structure of a business and the nature of its revenues. We advise businesses on optimising their tax position across the corporate lifecycle - from incorporation and initial structuring through to fundraising, expansion, and exit. This includes advice on the tax treatment of equity instruments, employee stock option plans, intercompany dividend flows, and the structuring of asset versus share acquisitions.

For businesses in high-growth or technology-driven sectors, we additionally advise on sector-specific tax incentives - including exemptions under the startup tax regime, SEZ benefits, and R&D-related deductions.

For businesses with cross-border operations, whether through foreign subsidiaries, overseas service arrangements, or international customer bases, international tax exposure requires proactive management. India has entered into Double Taxation Avoidance Agreements with over 90 countries, and navigating the interplay between domestic law and treaty provisions is essential for any globally-oriented enterprise. Our advisory spans Permanent Establishment exposure for entities operating across borders; the treaty characterisation of royalties, fees for technical services, and interest; the application of India's General Anti-Avoidance Rules and the Principal Purpose Test; and planning around Controlled Foreign Corporation rules in counterpart jurisdictions.

Intra-group transactions, technology licensing, management services, treasury functions, and financial guarantees, must be priced at arm's length under India's transfer pricing regime. Non-compliance carries significant consequences: disallowance of deductions, addition of deemed income, and penalties that can materially affect group profitability. We advise on benchmarking controlled transactions, preparing transfer pricing documentation including Master File and Country-by-Country Reporting for qualifying groups, and representing businesses in transfer pricing audits and Advance Pricing Agreement proceedings.

The application of GST to platform-based and technology-driven business models continues to raise novel and unresolved questions. We advise on the GST characterisation of products and services, place of supply determination for cross-border transactions, input tax credit eligibility, and compliance architecture for multi-state operations.