Our International Tax Services helps Foreign Corporates in addressing complex cross-border tax challenges with respect to investment and transaction structuring, holding company structures, group intellectual property assets, financing structures, the use of treaty networks, financial instruments and planning strategies to achieve and implement sound global tax policies.

Being internationally networked through BKR International having worldwide presence, we are well positioned to serve as a single-point source for providing international tax advice and approaches. A modern information technology backbone and an up-to-date knowledge management system helps our teams to keep abreast of the latest international developments. This equips us to pro-actively identify issues, suggest planning, and co-ordinate specializations across jurisdictions for discharging global tax assignments in a timely and cost-effective manner.

The Service Offerings primarily include as under:

  • Documentation and Representation Services for obtaining Permanent Account Number (PAN)
  • Preparation and Filing of Income Tax Returns of Foreign Corporates
  • Application for Exemption/Concessional Withholding Tax of Foreign Corporates
  • Representation of Foreign Corporates, Firms, Individuals before Income tax authorities
  • Advice and assistance in seeking advance rulings from the Authority for Advance Rulings in India on international tax issues
  • Advisory on Corporate and Withholding Tax Matters
  • Evaluation of tax treaties to examine taxability and availability of tax treaty relief
  • Devising a tax effieint secondment /transfer of employees model
  • Assistance in obtaining Tax Clearance Certificates
  • Representation before judicial authorities in assessments and appeals
  • Assistance in preparation and filing of Personal Income Tax Returns
  • Assistance in preparation and filing of Corporate Income Tax Returns
  • Assistance in preparation and filing of Withholding Income Tax Returns
  • Managing State Level Taxes/Compliances
  • EPC contracts-Pre Bidding Assistance & Formation and Contract Structuring for bidder
Transfer Pricing

The enactment of Transfer Pricing Laws in India in 2001 brought the issue of Transfer Pricing to the forefront amongst the various multinational corporations operating in India as well as Domestic Entities. Transfer Pricing is one of the critical tax issues for businesses having international operations wherein substantial efforts and resources needs to be invested. Irrespective of their size, organizations need an effective and dependable Transfer Pricing policy, which takes into consideration the organization’s overall business strategy and operating structure.

Besides drawing the attention of revenue authorities worldwide, Transfer Pricing is one of the most challenging tax issues and a key influence on a company’s worldwide tax burden. It impacts every aspect of the supply chain – R&D, procurement, manufacturing, marketing, distribution and customer support. This intense scrutiny implies significant risks for the unwary and the unprepared, particularly in a complex field such as transfer pricing where each transaction must be analyzed under its own unique facts and circumstances.

We advise our clients about possible tax risks and help in mitigating tax exposures from pricing of international transactions and thereby, enhancing their global resources and profit margins. We carry out analysis by considering market-based transfer pricing techniques (market risk, business risk, functional analysis, Assets Analysis, value-chain, supply chain management and business structure analysis, industry analysis, analysis on data bases etc.), benchmarking study, and exact assessment methodologies to design inter-company transfer pricing policies adopted in sound business approach and well-established similar industry’s principles.

Globally Revenue Authorities have become more aggressive in the international transactions among Associate Enterprises, Introducing a Stricter Regulatory Requirements & Documentation.

Our service offerings include:

  • Advance pricing agreements (APAs)
  • Tax controversy and dispute resolution
  • Documentation & planning
  • Value Chain Transformation / Global structure alignment
  • Specified Domestic Transactions (Domestic TP)
Tax Dispute Resolution Panel

Our Tax Dispute Resolution Practice provides perceptive and experienced advocacy on behalf of clients in tax disputes on a pan national basis. We represents clients at all stages from assessments to administrative and appellate remedies to resolve disputes. We serve at all levels of appellate remedy from first appeals before the Appellate Commissioners to Tribunals, Courts as well as Authority for Advance Rulings.

Our Tax Dispute Resolution team seeks to offer unique blend of Tax Experts, Lawyers and Accountants, who are involved with the clients from the planning stage to dispute resolution stage. We have rich experience in handling national and multinational clients, their international structuring of transactions, their transfer pricing policies and documentation, their connected assessments and dispute resolution.

Our expertise in substantive and procedural law, national and international practices helps us to evolve a coherent and consistent strategy to dispute resolution. Our Tax Dispute Resolution Practice comprises lawyers, accountants and economists who carry long and successful track record of assisting taxpayers on a broad array of domestic and international tax issues. We work on seamless basis to assist clients in resolving tax controversies.

Expatriation Services

In recent times, there is an increased attention on the expatriate population with several changes being brought in various legislations. This has resulted in increased responsibilities and additional compliance requirements.

We offer Expatriate Services in India to a large number of expatriates working in India including senior executives and management personnel of Medium and Large Enterprises. Our services includes tax efficient structuring of pay packages, assistance in compliance under tax laws and representation before tax authorities. We have a team of experts having profound knowledge of every aspect of such services. An expatriate coming to India has to comply with various procedural formalities in India.

We render following services to our expat clients:


  • Arranging meetings for Entry Interviews
  • Determination of residential status in India
  • Interpretation of DTAA with a view to optimize tax liability in India
  • Application to Tax Authorities for allotment of a Permanent Account Number (Tax Registration)
  • Arranging meetings for Exit Interviews
  • Assistance in Application to Tax Authorities for allotment of a Tax Deduction Account Number (Employer withholding Tax Registration)
  • Income Tax Clearance formalities prior to leaving (ITCC) (Non domicile)
  • Services for disclosures of foreign assets of Expatriates depending upon their Residential Status
  • Various compliances in regard to repatriation of funds/investments/property, etc


  • Assistance in Tax Withholding Computations or Tax Equalization Computations
  • Revision in tax computation/increment/changes in remuneration structure
  • Form 24Q – 4 returns during the year (This is the statutory form for the quarterly returns of taxes deducted at source by the employer on salary payments)
  • Form 24Q – 4 returns during the year (This is the statutory form for the quarterly returns of taxes deducted at source by the employer on salary payments)
  • Certificate in Form 16 and Form 12 BA (This is a statutory certificate issued to the employee certifying the taxes deducted at source and benefits respectively)
  • Preparation of tax challan forms for deposit of taxes into government account (as may be applicable)
  • Return Preparation and filing
  • Amended of Tax return
  • Compliances of Wealth-tax Act, etc
  • Advising suitable tax saving investments
  • Representation before tax authorities, in case required
Inbound Investments

India, a member of the BRIC countries has one of the highest GDP growth rates amongst Emerging Economies. Despite a seemingly adverse business climate, it continues to remain an attractive investment destination in the global market. In the past decade, Multinational Enterprises (‘MNE’) from different parts of the world have invested in India through the Foreign Direct Investment (FDI) route. Coupled with the business opportunity is the challenge of dealing with the Indian Tax and Regulatory environment. Key decisions regarding investments, income repatriation, taxation of income, goods and services etc. need validation and efficient management.

We offer end-to-end Advisory and Planning support for investment initiatives in India, followed up with Compliance and Regulatory support service.

Based on the business requirement, We provides comparative analysis and advice regarding forms of business presence such as Company, Branch office, Project office, Liaison office and others.

We enables MNEs to develop an efficient investment structure that is significantly dependent on the end-objective of investment. We assists in evaluating various investment instruments such as Equity, Convertible Preference Shares or Debentures and the like.

Besides the above stated issues, We have expertise in identifying and analyzing state-wise incentives & subsidies available to new industries being set up. Further, We supports MNEs desiring to invest in India with mapping of operational and logistics cost with the background of overlapping tax legislations.

Our services areas follows:-

  • Establishing a business presence in India
  • Obtaining necessary regulatory approvals from the Reserve Bank of India, the Foreign Investment Promotion Board, Government of India and other Regulatory Authorities
  • Making documentation and Filing regulatory approvals covering approvals from the Reserve Bank of India, the Foreign Investment Promotion Board, Government of India and other Regulatory Authorities
  • Review & finalizing shareholders, joint venture and other relevant business agreements
  • Routing Investments in India
  • Structuring investment in Indian Entity
  • Incentives/Subsidies For Setting up Industry
  • Compliance with FDI Regulations
  • Operating Tax Structure such as Customs Duty(for imports in India), Excise duty(for manufacturing), Service Tax(tax on services), VAT(tax on sale of goods) act
  • Structuring of cross bordered transactions i.e. Royalty, Technical fees, Dividend
  • Repatriation of Income and Investment