CORPORATE AND INTERNATIONAL TAX ADVISORY

OVERVIEW

Direct Tax is a critical consideration for deal structuring, M&A as well as conducting regular business. The corporate and international tax advisory practice encompasses a wide range of clientele such as corporates, limited liability partnerships, funds, trusts and HNIs.

ROLE

As part of the corporate and international tax advisory practice, Acuity Law provides the following services to clients:

1. Corporate and international tax covering analysis of:

  • Double taxation avoidance agreement interpretations

  • Holding company structures in foreign jurisdictions

  • Strategies for mitigating Permanent Establishment exposure

  • Place of Effective Management and GAAR impact

  • Dispute assistance (litigation strategy including drafting and appearance)

  • Withholding taxation, compliance, and reporting requirements

  • Profit distribution methods from a tax and regulatory angle

2. Strategies for acquisitions, mergers, divestitures, diversification or consolidation of businesses to achieve desired commercial goals effectively including:

  • Inbound structuring for entry into India, including jurisdiction analysis

  • Externalization structures/ outbound structuring for investment outside India

  • Fund taxation (including Offshore Fund and AIF) and Carry structuring

  • Tax Due Diligence on Indian targets

  • Group holding structures

  • Profit repatriation strategies for stakeholders

  • Endowment planning / wealth planning strategies

Frequently Asked Questions

Income Tax: Indian Income Tax Law is governed by the Income-tax Act, 1961 (Act) and rules made thereunder. Amongst other things, the Act chiefly governs the situs of taxation, tax residency, charge of tax, classification of income, incentives / tax holidays / exemptions, tax rates and withholding of taxes, transfer pricing (or base erosion of profits test) and other anti-avoidance provisions. India has also entered into double taxation avoidance agreements with various countries.

Here we answer some of the common queries relating to applicability and scope of the Act.