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.
Who it's for
- Indian companies making foreign investments or receiving overseas income
- Foreign subsidiaries and JV partners entering the Indian market
- Businesses with related-party imports, royalties, or management fees
- Groups requiring transfer pricing documentation and benchmarking support
Deliverables
- Transaction tax structuring memo — Indian and treaty implications
- Withholding tax analysis and Form 15CA/CB support
- Transfer pricing study, benchmarking, and documentation (Master/Local file elements)
- Advance ruling or APA advisory where appropriate
- FEMA reporting coordination with RBI compliance requirements
Our approach
- 1Map transaction flow — parties, functions, risks, and substance
- 2Analyse Income-tax Act, 2025 provisions and applicable DTAA articles
- 3Recommend structure balancing tax efficiency and regulatory acceptance
- 4Document contemporaneously for audit and TP defence
- 5Coordinate with legal counsel on agreements and regulatory filings
International tax mistakes are expensive and hard to unwind. We advise with conservative, document-backed positions suited to how Indian tax authorities actually examine cross-border cases.
International tax advisory is delivered from Delhi and Gurgaon for Indian headquartered groups with global operations or inbound investors.
Discuss your cross-border structuring requirements
Speak directly with a PJRJ specialist — we respond within one business day.