The multinational corporations have changed the fundamentals of business growth opportunities around the world. Companies are adapting new revenue policies and accepting new challenges in this competitive market. With more complexities, the tax & regulatory compliance is changing constantly in the global market. In India, the tax & regulatory affairs are shifting towards a new horizon. The implementation of the tax revenue collection through digitization and by the source of e-governance is in process.
DVKS and Associates has a team of dedicated international tax practitioners & professionals. With technical knowledge and experiences in practical fields, we can help the multinational corporations to manage the risks of multiple tax processes and regulations across the globe.
Understanding this need of the entities, DVKS and Associates offers a complete spectrum of international tax services which include:
International And Cross Border Taxation
Our international tax professionals help entities address various concerns pertaining to cross border transactions.
Understanding the business of the entity and the transactions undertaken and help structure these in order to mitigate the risk of Permanent Establishment (PE) exposure
Advisory on cross border transactions to help manage Permanent Establishment (PE) exposure and also minimize double taxation
Inbound tax advisory/outbound tax advisory
Identifying competitive supply chain to drive efficiencies for existing and target markets
Assist in tax efficient repatriation of funds
Help understand the applicability/mitigation of withholding taxes on cross border payments (royalties, interest, fees for technical services)
Understanding the impact of POEM regulations on entities at the group level evaluating these in the light of the Indian regulations and comparing these with the POEM regulations adopted globally
BEPS and GAAR Advisory
Analysis of Double Taxation Avoidance Agreement
A double taxation avoidance agreement (DTAA) is signed between two or more countries with the objective that tax – payers in these countries can avoid being taxed twice for the same income.
Keeping in mind the transactions undertaken by the entity, we help understand the tax implications of such transactions in the light of the tax treaty to ensure the elimination of double taxation, advice on the withholding tax rates as per the Income Tax Act vis-à-vis tax treaties.
Transfer Pricing
Transfer pricing (TP) has grown into one of the most contentious issues worldwide. Entities not only need to plan their international transactions within the existing framework but also need to plan in anticipation of future uncertain tax policies. Keeping this in mind at DVKS and Associates ,we offer optimized solutions – planning, compliance & advisory services:
Formulating and implementing global transfer pricing policy.
Review existing TP policy and ensuring adherence.
Assisting in valuation of business associated with business restructuring, mergers, and acquisitions etc.
Maintenance of robust documentation as per applicable laws and assisting in compilation of master file and country specific documentation.
Benchmarking support
Audit under Transfer Pricing and Issue of 3CEB as required by the Indian Income Tax Laws
Drafting and review of inter - company agreements
Representation before tax authorities & Litigation
Due diligence from transfer pricing perspective.
Advice on BEPS readiness and implementation , the applicability of master file and country by country reporting (CBCR) requirements, functional and comparability analysis, advise on transfer pricing risk analysis and alignment with group’s master file
Advance Pricing Agreements (APA), Mutual Agreement procedures (MAP), Safe Harbour applications and transfer proceedings.
Expatriate Taxation
Very often entities are faced with issues pertaining to expatriate taxation. We provide comprehensive solutions to various issues faced by entities pertaining to expatriate taxation
Determination of residential status on expatriate employees in India and the incidence of the tax on income earned
Formulating employment compensation structures in light of the Income Tax Act
Computation of withholding taxes from salaries of expatriate employees and filing of withholding tax return
Structuring employment agreements for expatriate employees with a view to mitigate the risk of Permanent Establishment (PE) for overseas employers in India
Preparing and filing of personal income tax returns.
