International and Withholding Tax Law Firm

International and Withholding Tax Law Firm

International taxation is the study or determination of tax on a person or business subject to the tax laws of different countries, or the international aspects of an individual country's tax laws as the case may be. Governments usually limit the scope of their income taxation in some manner territorially or provide for offsets to taxation relating to extraterritorial income. The manner of limitation generally takes the form of a territorial, residence-based, or exclusionary system. Some governments have attempted to mitigate the differing limitations of each of these three broad systems by enacting a hybrid system with characteristics of two or more.

Withholding tax is a machinery provision applicable to the taxpayer on the income which is chargeable under the Income Tax Act 1961 to enable easy collection and recovery of tax from payments made to non-residents and foreign companies. The concept is based on source rule where the tax is deducted in the country from which the payment is made.

How We May Assist You

The interpretational issues between the taxpayer and authorities in withholding tax and international tax have raked up substantial litigation, especially in the last few years. Our Tax team regularly advises multinational corporations on the areas such as withholding tax, cross-border investment, transaction structuring, international tax treaties, repatriation & exit arrangement, permanent establishment etc. Our Tax team regularly advises multinational companies in:

1. Advisory, compliances and refund of Withholding Tax
2. Tax efficient structuring of inbound & outbound investments, M&A advisory, domestic/group restructuring
3. Advisory on double taxation avoidance agreement, permanent establishment, Place of Effective Management (POEM), etc
4. Review of transaction/arrangement and analyse the impact of Base Erosion and Profit Shifting (BEPS) measures
5. Advisory on the foreign taxes applicable to the companies registered in India

Our team regularly advises on the withholding tax applicable to non-resident and foreign companies and representation to the authorities for the refund, and lower withholding tax in India. We have extensive experience in strategic tax solutions in areas such as inbound & outbound strategy, repatriation & exit strategy & domestic or group restructuring, and tax treaties advisory for companies in Germany, USA, UAE, United Kingdom, Spain and many others.