International Taxation

 

Cross border transaction and investments have caused uncertainty in tax matters which lead to ambiguity and uncertainity in taxation of cross border transactions. International tax treaties have tried to obviate the pain through.

 

  • Elimination of double taxation
  • Certainity of tax treatment
  • Reduction in tax rates.
  • Lower compliance costs
  • Prevention of fiscal evasionĀ 
  • Prevention of tax discrimination
  • Resolution of tax disputes
  • Tax sparing

 

International taxation caters to a host of areas like:

 

  • Independent Personal Services
  • Dependent Personal Services
  • Permanent Establishment & Taxation of Business Income
  • Non-discrimination and Mutual Agreement Procedure
  • Taxation of income from immovable properties
  • Taxation of income from interest/dividend/capital gains
  • Taxation on income of Entertainers and Athletes
  • Advance Rulings
  • Taxation of Income from Shipping and Air Transport Services
  • Thin Capitalization
  • Controlled Foreign Corporations.
  • Beneficial Ownership
  • Partnerships
  • Royalties and Fees for Technical Services
  • Most Favoured Nation (MFN) Clause.
  • Withholding Tax
  • Transfer Pricing
  • Mergers and Acquisitions
  • Hybrid Financial Instruments
  • Principles of jurisprudence.

 

International Taxation is a complex subject that should be tackled only through professional advisory and consultancy. Our guidance helps in ascertaining the precise tax liability, tax planning, minimisation of double taxation. We also advice in making investments through the most appropriate route.