Practice Area 10

International Taxation & Transfer Pricing

Advisory and representation on cross-border tax, treaty positions and transfer pricing, from policy design through to proceedings.

Reference volumes and printed schedules of figures on a desk

What we do

International Taxation & Transfer Pricing

We advise on cross-border transactions, treaty positions, permanent establishment and withholding tax, and on the tax consequences of group structures and of the contracts that sit under them. Global contracts are reviewed from a tax perspective before they are signed rather than after.

On transfer pricing we design policy, prepare documentation and benchmarking studies, and defend pricing positions through assessment and appeal. We appear in transfer pricing and direct tax matters before the Dispute Resolution Panel, the Income Tax Appellate Tribunal and the Hon'ble High Courts, and make applications under the Right to Information Act in connection with bilateral Advance Pricing Agreements.

Typical matters

Work we are asked to do

  • Cross-border transactions, treaty positions and permanent establishment
  • Withholding tax on cross-border payments
  • Transfer pricing policy design, documentation and benchmarking
  • Transfer pricing assessment and Dispute Resolution Panel proceedings
  • Appeals before the Income Tax Appellate Tribunal and the High Courts
  • Global contract review from a tax perspective

Who we act for

Clients in this practice

  • Indian companies with operations overseas
  • Multinational groups operating in India
  • Promoters and investors in cross-border structures
  • Companies facing a transfer pricing assessment
All ten practice areas