With its International Tax & Transfer Pricing services, KPSA's goal is to help clients in managing the complexities arising out of multiple tax systems and cross-border challenges. KPSA’s tax team comprises of dedicated tax professionals with in-depth technical knowledge and practical experience in the area on international tax and transfer pricing. Our tax team undertakes detailed analysis on various alternatives and advise on setting up optimum and efficient holding structures/business models which helps client in mitigating the exposure on account of Permanent Establishment, Place of Effective Management (POEM), General Anti Avoidance Rules (GAAR), Base Erosion and Profit Shifting (BEPS), and other international tax aspects.
KPSA’s international tax and transfer pricing services covers following service areas:- 1. Planning & Advisory: Careful tax planning is critical for business success in an unpredictable global economy as well as constantly changing tax laws in developing as well as developed countries and constant changes in the International Taxation principles. Our team assists in planning the Optimum Group (Global business) Structure as also overall TP strategy and policy for the International Group. Our dedicated international tax professionals assists in the following tax aspects: a) Global Investment Structure - KPSA’s expertise enables clients to implement a structure in India by setting up tax-efficient operating vehicles as also investment instruments and analyse alternative investment jurisdictions. This would include exit planning, repatriation streams, capital structures, transfer pricing planning etc. b) Providing of Transaction Advisory from TP perspective c) Global TP policy - Undertaking of TP Planning/Benchmarking analysis - KPSA helps multinationals develop and implement commercially feasible and fiscally efficient TP policies. d) IPR related Holding Structure and Transfer Pricing advisory e) Framing and developing optimum remuneration structures for expatriates and advising in developing employee policy in a manner which safeguards client from the Income-Tax / TP exposure f) Evaluating and mitigating Permanent Establishment exposure for a foreign corporation in India
2. Compliance: a) India TP regulations prescribe rigorous mandatory documentation requirements and impose steep penalties in case of non-compliance. Thus, multinationals need to ensure they comply with documentation and compliance requirements and also ensure that a system is in place for future compliances. KPSA can help you meet your documentation and compliance requirements in following areas: i) India TP compliances ii) Global TP documentation iii) Country-by-country Report (CbCR) b) Global Compliance Tracker - Providing Assistance in carrying out compliances at various jurisdictions where investments have been made by the Group through source country experts c) Assistance in availing optimum foreign tax credit in line with provisions of various Tax Treaties as also the laws of relevant source countries 3. Dispute Resolution: Professionals @ KPSA have extensive experience in dealing with the Indian tax and appellate authorities. KPSA provides guidance on the eligibility, feasibility and period for which the alternate dispute resolution mechanisms, as listed below, can be availed by the client. a) Advance Rulings b) Advance Pricing Agreements c) Mutual Agreement Procedure d) Safe Harbor rules
4. Representation & Litigation: Professionals @ KPSA has extensive experience of guiding client in responding to tax authority challenges. Leveraging on vast experience, our professionals can work with you to help prepare effective responses for submission with the tax authorities, preparing robust economic analyses, assist in fortifying appellate strategies and provide guidance in devising supportable defense at all appellate levels.
With the very strong team of Chartered Accountants and lawyers with extensive experience in the field of litigation, KPSA’s litigation practice provide following key services: a) Understanding the case and issue on hand and assisting in guiding clients on the next course of action b) Assisting in preparing an adequate response / papers to be filed with the Tax office after thorough and relevant research for the matter under review c) Assistance in maintaining proper documentation d) Assistance in Representation before the Tax Authorities for Tax Assessment proceedings etc. e) Assistance in Representation before the Appellate Authorities which includes - i) Representation before Commissioner (Appeals) ii) Representation before Income-Tax Appellate Tribunal (ITAT) f) Assistance as a briefing counsel in representing the case at High Courts and Supreme Court. g) Assisting in filing adequate responses to penalty and prosecution notice issued by the Tax office based on the matter under review h) Assisting in filing adequate responses for obtaining ‘stay’ based on the matter on hand i) Assisting in filing of writ petition before the High Court in appropriate cases where necessary
5. Desktop review of overseas tax and regulatory aspects: We assist client in understanding their queries with respect to tax or regulatory aspect of jurisdictions other than India and assist them in providing our preliminary understanding based on our interpretation of those foreign laws. We further assist in comprehensively addressing the issue post taking necessary confirmations from the subject matter expert and the consultant practicing in such overseas jurisdiction.
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