International Taxation & Transfer Pricing
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International Taxation & Transfer Pricing

Expert guidance on cross-border transactions, transfer pricing, and NRI taxation services.

Detailed Overview

In an increasingly globalized economy, businesses and individuals are frequently involved in cross-border transactions. These activities bring unique tax challenges and opportunities. CA Mahendra Lal provides expert international tax advisory and compliance services to help you navigate the complexities of global tax laws. Transfer Pricing Services: Transactions between related parties across borders must be conducted at 'Arm's Length Price' (ALP) to prevent tax evasion. We assist businesses in formulating transfer pricing policies, maintaining mandatory documentation, and filing Form 3CEB. Our team also represents clients during transfer pricing audits and litigation. DTAA Advisory and Compliance: India has signed Double Taxation Avoidance Agreements (DTAA) with over 80 countries. We help you leverage these treaties to ensure you don't pay tax on the same income in two countries. This includes advising on the withholding tax (TDS) rates for foreign remittances and obtaining Tax Residency Certificates (TRC). Inbound and Outbound Investment Advisory: For foreign companies looking to invest in India, we provide comprehensive entry-strategy advisory. This includes choosing the right business vehicle (Subsidiary, Branch Office, or Project Office) and ensuring compliance with FEMA regulations. Similarly, we assist Indian businesses looking to expand abroad with their outbound investment structures. NRI Taxation: Non-Resident Indians (NRIs) often face complex tax issues regarding their income in India, such as rental income, capital gains on property, or interest. We provide specialized NRI tax services, including return filing, 15CA/15CB certification for money transfers abroad, and advisory on tax-efficient repatriation of funds.

Key Features & Scope

Transfer Pricing Documentation and Certification
Advisory on Double Taxation Avoidance Agreements (DTAA)
Filing of Form 3CEB for International Transactions
Withholding Tax Advisory (Section 195/15CA/15CB)
Expatriate Taxation and Payroll Support
FEMA and RBI Compliance for Foreign Investment
Advisory on Permanent Establishment (PE) Risks
NRI Income Tax Return Filing and Management

Our Methodology

1

Analysis

Reviewing the nature of international transactions and the countries involved.

2

Treaty Review

Identifying applicable DTAA provisions to optimize the tax burden.

3

Documentation

Preparing robust transfer pricing studies and required regulatory forms.

4

Certification

Providing CA certificates (15CB) for foreign remittances as required.

Frequently Asked Questions

What is an Arm's Length Price?

It is the price that would be charged between two unrelated parties in a similar transaction under similar conditions.

What is Form 15CA and 15CB?

These are forms required by the Income Tax Department to be filed before making any payment to a non-resident, ensuring that the appropriate tax has been deducted.

Who is considered an NRI for tax purposes?

A person is considered an NRI if they spend less than 182 days in India during a financial year (subject to other specific conditions).

Benefits

  • Avoidance of double taxation on global income
  • Mitigation of heavy transfer pricing penalties
  • Strategic tax-efficient cross-border structures
  • Compliance with complex FEMA and RBI regulations
  • Smooth repatriation of funds across borders
  • Minimized withholding tax through treaty benefits
  • Expert representation in international tax disputes
  • Clarity on the tax impact of global operations

Need Assistance?

Speak with our expert consultants today about your specific requirements.

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