International Taxation and Transfer Pricing

For groups whose value crosses a border, exposure is decided by structure long before it is decided by filing. We advise at the structuring stage and defend the position afterwards.

Overview

Cross border tax is the area where a decision made casually at incorporation becomes expensive five years later. Treaty access, permanent establishment risk and related party pricing all follow from how the group was assembled. We prefer to be consulted while that is still a choice.

Work in this practice is delivered under the same operating standard that applies across the firm. The compliance calendar is mapped at the outset and driven by us, positions involving judgement are documented with the authority relied upon at the time they are taken, and nothing is filed or issued without an independent internal review by someone other than the preparer.

Where a matter touches another practice area, and most do, it is handled inside the same file rather than referred outward. That is the point of holding these disciplines together.

Common questions

At what size does transfer pricing documentation become necessary?

The thresholds have moved down considerably and now catch mid sized businesses with modest related party transactions. We assess applicability against your actual transaction values rather than assuming you are below the line.

Can you advise on both the Indian and overseas side of a structure?

For the India and UAE corridor, yes, as a single engagement through our UAE desk. For other jurisdictions we advise on the Indian position and coordinate with your overseas advisors so the two views reconcile.

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