International Taxation for Companies in India

Transfer pricing rarely stands alone. We advise on the full cross-border tax picture — permanent establishment, withholding tax, thin capitalisation and structuring — for companies operating in India.

Overview

TP and international tax, handled together

A related-party transaction rarely raises only a transfer pricing question — it usually has a withholding tax angle, a permanent establishment angle, or an interest-deductibility angle too. We look at the whole picture, not just the TP slice.

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Who this applies to

Indian entities of multinational groups, foreign companies with an India presence, and Indian companies investing or operating overseas.

What We Cover

The full cross-border tax picture

PE Exposure & Attribution

Permanent establishment risk assessment and profit attribution analysis.

Withholding Tax & DTAA

Treaty analysis, Form 15CA/15CB and lower/nil withholding certificate applications.

Thin Capitalisation (Sec 94B)

Interest deduction limitation analysis for excess interest to associated enterprises.

Cross-Border Structuring

Tax-efficient structuring for inbound investment, outbound investment and business restructuring.

Our Process

A single, integrated tax position

Step 1

Structure Review

Map your cross-border transaction and holding structure end-to-end.

Step 2

Risk Assessment

Identify PE, withholding tax and interest-limitation exposure.

Step 3

Treaty Analysis

Determine applicable DTAA benefits and compliance requirements.

Step 4

Integrated Advisory

Align TP, withholding tax and structuring positions into one coherent strategy.

Why Work With Us

One team, one consistent cross-border tax position

Integrated Advisory

TP and international tax advised together, not in silos.

Treaty Network Depth

Experience across India's major DTAA partner jurisdictions.

Legal & Tax Together

Lawyers and Chartered Accountants working on the same file.

FAQs

Common questions

What triggers Section 94B interest limitation? +

Section 94B limits the deduction of interest expense paid to an associated enterprise abroad where it exceeds 30% of EBITDA (subject to a de minimis threshold and specified exceptions for banks and NBFCs).

Do I need a lower withholding tax certificate for every cross-border payment? +

Not always, but it's often advisable for recurring payments like royalty, fees for technical services, or interest, to avoid over-withholding and the administrative burden of claiming a refund.

Need an integrated TP and international tax review?

Book a free consultation with our team.