International Taxation

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.

We at TransPrice being team of expert in transfer pricing & international taxation help our client in various aspects related to international taxation such as:

  • International transaction tax planning
  • Interpretation of Double Tax Avoidance Agreements (DTAAs) and its implementation and advisory
  • Business modelling and re-modelling including implementation of tax effective operational models
  • Designing and implementation of global structures and company incorporations
  • Analysis for Permanent Establishments and their tax impacts
  • Strategies for achieving efficient ‘Effective Tax Rates (ETR)’
  • Tax optimized cash repatriation strategies
  • Business valuations
In addition to the above services, we also provide support to our clients in below mentioned area which are very important when a company is doing business in international market.

General Anti- Avoidance Rules (GAAR)

GAAR is an analysis of ‘Substance over Form principle’ in the territory of tax practice. With the advent of GAAR, every structure implemented by the company would be analyzed keeping in mind the tax benefit motive for the company. Ignorance to GAAR provisions can get you caught you in the web of tax avoidance with heavy tax and penalty implications.

Considering the importance of GAAR even in the tax audit, we provide certification for various implemented structures from a GAAR perspective. This could help you and your company in tax audit as well as tax assessments. In addition we provide advisory on GAAR implications for your company.

Having written a professional book on the subject matter of GAAR, we are well positioned to provide you expert services on the subject matter.

Base Erosion and Profit Shifting (BEPS)

Every company doing business outside its home country should assess their business model for BEPS impact to understand the risk they would be carrying. We help companies for BEPS impact assessment. This typically involve following phases: