International Tax Planning Advisory

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Transaction Advisory Services


At Pratapkaran Paul & Co, our Transaction Advisory Services are tailored to guide businesses, investors, and stakeholders through critical financial, legal, and operational decisions with confidence. Whether you're planning a merger, acquisition, business expansion, or strategic exit, our multidisciplinary experts deliver comprehensive due diligence, independent business valuation, and forensic audit investigations that uncover risks, validate opportunities, and protect your investment interests.

  • We also provide succession planning advisory for family-owned enterprises, startups, and corporates aiming to ensure smooth leadership transitions and preserve wealth across generations. For global clients and NRIs, our India entry strategy services support the full lifecycle — from entity structuring, regulatory approvals (FEMA, RBI), tax planning, and incorporation, to local compliance and post-entry business advisory.
  • With deep sectoral expertise and a commitment to actionable insights, we empower businesses to make informed decisions and navigate complex transactions seamlessly. Whether you're searching for “best due diligence services in India” or “how to enter Indian market as a foreign investor,” our Transaction Advisory team is your trusted partner.


Pratapkaran Paul & Co.,(PKP),Chartered Accountants

International Tax Advisory Services for Foreign Businesses Expanding into India

Entry Strategy & Tax Planning for Foreign Investors

  • Tailored international tax consulting for companies entering India
  • Tax-efficient structuring for joint ventures, subsidiaries, and branch offices
  • Comprehensive analysis of business models, fund structures, and entity selection
  • Legal and regulatory guidance for setting up liaison, branch, or project offices
  • International tax advisory on capital repatriation and profit distribution
  • Assistance with FEMA and RBI compliance related to foreign investments

Fund Setup & Operational Tax Strategy

  • Expert advice on setting up funds and investment vehicles in India
  • Tax treatment of fund operations and investor return structures
  • Assessment of tax impact on pooled investments and AOP formation
  • Structuring for venture capital funds and private equity investments
  • Addressing taxability on foreign income earned by domestic funds

Cross-Border Structuring & M&A Support

  • Designing optimal holding structures for inbound investments
  • Advisory on direct and indirect tax implications for M&A transactions
  • Strategies for asset transfer between Indian and foreign entities
  • Analysis of buy-sell agreements for international business acquisitions
  • Structuring cross-border mergers for tax efficiency and compliance


Permanent Establishment (PE) Analysis

  • Evaluation of business presence to determine PE exposure in India
  • Assistance with documentation to avoid unintentional PE creation
  • Tax planning for head office overhead allocation and chargebacks
  • Interpretation of tax treaties to minimize tax liability
  • Guidance on fixed place, service, and agency PE classifications


Taxation of International Services and Royalties

  • Assessment of royalty and technical service agreements
  • Analysis under Indian Income-tax Act and Double Taxation Avoidance Agreements (DTAA)
  • Tax implications of secondment agreements and remote service delivery
  • Advisory on equalization levy and digital tax compliance
  • Strategic planning for intercompany service fees and royalties


Withholding Tax & TDS Compliance

  • Advisory on applicable TDS rates for payments to non-residents
  • Compliance planning for professional fees, interest, and royalty remittances
  • Application for lower/nil withholding certificates from tax authorities
  • Tax computation and filing for foreign recipients
  • Support in claiming foreign tax credits and avoiding double taxation



Global Tax Strategy for Indian Businesses Expanding Internationally



International Business Structuring & Outbound Investment Planning

  • Structuring international subsidiaries and overseas joint ventures
  • Analysis of regulatory and tax aspects of outbound investments
  • Selection of tax-efficient jurisdictions for global operations
  • Advice on treaty shopping and anti-abuse provisions
  • Assistance with FEMA and overseas investment regulations


Multi-Tier Holding Structures

  • Strategic design of layered international holding entities
  • Routing investments through low-tax jurisdictions
  • Evaluation of tax benefits under DTAA and GAAR implications
  • Planning exit strategies with minimal tax exposure
  • Addressing substance and operational control issues


Cross-Border Transactions & IP Planning

  • Structuring for ownership and transfer of Intellectual Property (IP)
  • Tax planning for royalty income and intangible assets
  • Managing licensing arrangements between global entities
  • Transfer pricing implications for IP and brand transfers


Residency & Foreign Tax Credit Optimization

  • Determining tax residency of Indian companies and promoters
  • Claiming foreign tax credits (FTC) in India efficiently
  • Managing double taxation through strategic tax treaty benefits
  • Maintaining documentation for FTC and CFC regulations
  • Advisory on anti-deferral and deemed income provisions


International M&A & Exit Structuring

  • Advisory on acquisitions, mergers, and divestments across borders
  • Planning capital gains tax and exit tax implications
  • Utilizing step-up basis and treaty relief on capital exits
  • Coordination with legal, finance, and tax advisors globally
  • Optimizing withholding and repatriation strategies


Multi-Tier Holding Structures

  • Strategic design of layered international holding entities
  • Routing investments through low-tax jurisdictions
  • Evaluation of tax benefits under DTAA and GAAR implications
  • Planning exit strategies with minimal tax exposure
  • Addressing substance and operational control issues