A dedicated international tax desk within PJRJ
Cross-border transactions trigger complex questions — permanent establishment, transfer pricing, withholding tax, treaty benefits, and FEMA compliance. PJRJ advises Indian businesses expanding overseas and foreign groups investing in India on structuring transactions to be tax-efficient, compliant, and defensible under Indian and treaty law.
Cross-border mistakes are expensive and difficult to unwind. Our international tax team advises with documented, defensible positions suited to how Indian authorities examine global structures.
- Transfer pricing documentation
- Cross-border structuring
- Withholding tax & 15CA/CB
- DTAA & treaty planning
- FEMA coordination
- APA & advance ruling support
- Inbound & outbound advisory
- Litigation defence support
International Tax services
Select a service for detailed scope, deliverables, and how we work.
Transfer Pricing
Documentation, benchmarking & defence for related-party transactions
View detailsCross-Border Structuring
Inbound & outbound investments — PE, substance & treaty planning
View detailsWithholding Tax
Section 394, Form 15CA/CB & treaty rate analysis
View detailsDTAA & Treaty Planning
Double taxation relief, LOB & substance requirements
View detailsFEMA Coordination
RBI reporting aligned with cross-border tax positions
View detailsWhy clients choose our international tax desk
Document-backed positions
Conservative, audit-ready advice — not aggressive structures that collapse on scrutiny.
Integrated deal support
Works seamlessly with our M&A, valuation, and due diligence teams on transactions.
Substance over form
Structures that reflect economic reality and withstand transfer pricing examination.
Delhi NCR base
Advisory from Delhi and Gurgaon for Indian groups with global operations.
How we work
- 1
Map transaction flow — parties, functions, risks, and substance
- 2
Analyse Income-tax Act, 2025 provisions and applicable DTAA articles
- 3
Recommend structure balancing tax efficiency and regulatory acceptance
- 4
Document contemporaneously for audit and TP defence
- 5
Coordinate with legal counsel on agreements and regulatory filings
- 6
Ongoing monitoring of regulatory and treaty developments.
Industries we serve
- IT & Software Services
- Manufacturing & Export
- Pharmaceuticals & Healthcare
- E-Commerce & Marketplaces
- Professional Services
- Infrastructure & EPC
Discuss international tax with a PJRJ partner
We respond within one business day — share your requirements for a free initial consultation.
International Tax FAQs
Common questions about our international tax services.
When is transfer pricing documentation mandatory?
International transactions above prescribed thresholds require documentation. We assess your related-party profile and prepare compliant studies and files.
Do you handle Form 15CA/CB for overseas payments?
Yes. We analyse the payment, determine withholding obligations, and support CA certification and portal filing.
Can you advise on both tax and FEMA for outbound investment?
Yes. We coordinate tax structuring memos with FEMA reporting requirements and legal documentation.