Treaty benefits require careful analysis of substance, beneficial ownership, and anti-abuse provisions. PJRJ advises on defensible treaty positions backed by documentation.
Our treaty analysis process
- 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 advisory is delivered from Delhi and Gurgaon for Indian headquartered groups with global operations or inbound investors.
Discuss your dtaa & treaty planning requirements
Speak directly with a PJRJ specialist — we respond within one business day.