Our international tax planning team helps foreign companies investing in India, and Indian companies expanding overseas, build structures that are efficient, defensible and compliant with Indian tax law, tax treaties, BEPS standards and FEMA.
Operating in more than one country can lower costs and open new markets, but it also exposes a business to two or more tax systems at once.
Without planning, the same profits can be taxed twice, a foreign company can unintentionally create a taxable presence in India, payments can suffer excess withholding, and structures can fail under anti-avoidance rules. Whether you are a foreign company investing in India or an Indian company going global, you need to understand how Indian tax law, the relevant tax treaty and the rules of the other country interact.
India's tax environment for cross-border business continues to evolve. The Income-tax Act, 2025 took effect from 1 April 2026. Tax treaties have been modified by the Multilateral Instrument. The General Anti-Avoidance Rule (GAAR), Place of Effective Management (POEM) and Significant Economic Presence rules apply, and the global minimum tax under BEPS Pillar Two affects large groups. We combine this India expertise with a trusted network of overseas accounting and legal firms, to give you one joined-up view.
| Rule | Why it matters |
|---|---|
| Double Taxation Avoidance Agreements | Decide where income is taxed, reduce withholding rates, and provide relief from double taxation |
| Multilateral Instrument (MLI) | Modifies many of India's treaties, including the principal purpose test and wider PE rules |
| GAAR | Allows tax authorities to deny benefits from arrangements whose main purpose is a tax benefit |
| Place of Effective Management (POEM) | A foreign company managed from India can be treated as an Indian tax resident |
| Significant Economic Presence | Can create a taxable business connection in India without a physical presence |
| BEPS Pillar Two | A 15% global minimum tax for large multinational groups in implementing jurisdictions |
| FEMA | Governs FDI into India, ODI out of India, round-tripping and repatriation |
With growing foreign investment in India comes demand for internationally mobile employees. We advise expatriates and their employers on residency, salary structuring and compliance.
We cover returns, treaty relief, NRO repatriation and Form 15CA/15CB for non-resident Indians with income or assets in India.
The growing number of intercompany transactions has made transfer pricing a leading risk area for global businesses. We provide TP studies, benchmarking, APAs and audit defence.
We map entities, ownership, flows of goods, services, IP and money, and your business plans.
We review PE, withholding, treaty eligibility, GAAR, POEM and TP risks.
We compare structures on tax cost, substance, compliance burden and commercial fit.
We work with our overseas partner firms to align advice in each country.
We prepare documentation, agreements, regulatory filings and opinions.
We provide ongoing compliance, law-change updates and support in assessments.
Tell us about your group and your plans. Our international tax team will identify the key issues and options, at no cost and with no obligation.
Book a Free International Tax ConsultationShare a few details about your group and plans. We usually respond within one business day.
