Tax

In an increasingly complex and evolving tax landscape, our Tax Practice combines deep technical knowledge with practical insight to deliver clear, commercially grounded, and solution-oriented advice. Our team comprises both lawyers and chartered accountants (CPAs), enabling us to offer an integrated perspective across legal, financial, and regulatory dimensions of taxation.

Our Tax Practice works seamlessly with our corporate, regulatory, and dispute resolution teams to provide clients with comprehensive and tailored tax solutions that align with their business objectives and strategic priorities.

We advise clients on a wide spectrum of direct and indirect tax matters, including mergers and acquisitions, inbound and outbound investments, private equity and venture capital transactions, corporate reorganisations, group restructurings, supply chain optimizations, divestments, tax due diligence, dispute resolution, and succession planning. We also assist clients with Customs and Goods & Services Tax (GST) classification, refunds, audit and investigation support, and provide legal opinions on complex tax issues.

Our expertise includes:

Direct Tax

Transaction Tax Services

• M&A / transactional tax services including complex domestic and cross-border M&A, joint ventures and demergers, as well as corporate reorganizations.
• Transaction and fund structuring
• Private Equity / Venture Capital - investments and exits.
• Inbound and outbound investment structuring. 
• Investment in and through GIFT city.
• Externalization / Internalization of a holding structure (especially start-ups).
• Corporate insolvency.
• Structuring and setting up of Global Capability Centre (GCC) in India.
• Tax due diligence (sell-side/buy-side).
• Execution support (including review of transaction documents).

Tax Advisory and Planning – Domestic and International Tax

• Identify and implement tax planning/optimisation strategies.
• Interpretation and application of International Tax Treaties read with Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
• Evaluate the applicability and implementation of the Pillar I and Pillar II solutions under Base Erosion and Profit Shifting (BEPS) 2.0 project.
• Applicability of general anti-avoidance rules (GAAR) provisions on any arrangement.
• Eligibility for claiming tax treaty benefits and issues pertaining to tax residency.
• Existence of Place of Effective Management (PoEM) of foreign company in India.
• Identify potential Permanent Establishment (PE) risk in India and suggesting potential risk mitigating strategies.
• Applicability of indirect transfer tax provisions by virtue of reorganization undertaken outside India.
• Complex transfer pricing issues.
• Withholding tax obligations.
• Identify strategies for tax efficient repatriation of surplus cash from India.
• Analysis and advise on transactions in Virtual Digital Assets.
• Employee Stock Options – structuring and tax advisory.
• Structuring and setting up charitable institutions.
• Structuring offshore and onshore funds and covering structure for general partners.

Transfer Pricing

• Formulation of group transfer pricing policies in line with global operating models.
• Business structuring and remuneration models for inter-company transactions.
• Drafting and review of inter-company agreements to align with arm’s length principles.
• Review of benchmarking analysis and coordination for preparation of transfer pricing study reports.
• Review and assistance with transfer pricing compliances, including certification (in Form 3CEB), local file documentation and Master File.
• Advisory and representation in Safe Harbour applications and Advance Pricing Agreement (APA) filings.
• Litigation support before tax authorities and appellate forums in relation to transfer pricing disputes.

Indirect Tax

Goods and Services Tax

• Advisory on classification, applicable tax rates and exemptions.
• Advisory on valuation of supplies, including on transactions with related parties.
• Advisory on eligibility of input tax credits and applicable restrictions.
• Advisory and assistance on issues relating to debit and credit notes.
• Advisory on implications for deeming provisions specifically made applicable to certain specified supplies, including e-commerce suppliers and online gaming suppliers.
• Advisory on registration requirements, particularly for non-resident operators rendering digital services in India jurisdiction.
• Advisory on issues relating to time of supply and place of supply.
• Advisory on eligibility to claim refunds under GST laws, including in relation to inverted duty structures, exports and supplies made to SEZ units.
• Supply chain optimization to achieve tax efficient structures.
• Advisory on amnesty schemes, including cost benefit analysis to identify matters suited for amnesty and for successful discharge under such schemes.
• Advisory on issues relating to tax collection and tax deduction.

Customs and International Trade

• Advisory on customs valuation and classification exercises.
• Advisory on valuation issues involving related party transactions and import/export transaction risk reviews.
• Advisory on export and import restrictions under the Foreign Trade Policy.
• Guidance on use of preferential rates under India’s CEPA/FTA frameworks (India–UAE CEPA, ASEAN, SAFTA, Indo–Korea, Indo–Japan, etc.), origin certification, and cost-benefit evaluations.
• Advisory to export entities on the legal and regulatory framework governing business operation set up in units such as SEZs, EOUs, STPIs, and Free Trade Warehousing Zones, including a comparative assessment of the advantages and limitations of each structure, tailored to the client’s specific business requirements and operational objectives.
• Assistance on compliances required by import/export entities like registration for IEC, STP/non-STP license, ICEGATE registration etc.
• Advisory on applicability of exemption notifications and concessional rate notifications.
• Advisory and assistance in relation to licensing, classification, and end-use certification under SCOMET (Special Chemicals, Organisms, Materials, Equipment, and Technologies) for dual-use goods and technologies.
• Advisory and assistance in relation to implementation of Internal Compliance Programmes (ICPs) aligned with DGFT and OFAC best practices.
• Advisory on sanctions and export restrictions, including applicability of U.S. OFAC, EU, and other foreign sanctions regimes to Indian businesses and supply chains.

Tax and International Trade Litigation and Dispute Resolution 

• Developing litigation strategies.
• Providing opinion / memos on matters pending dispute resolutions.
• Filing of applications with Authority for Advance Rulings (AAR) in relation to direct and indirect tax matters.
• Representation against import restrictions arising from international trade regulations, including under Foreign Trade Policy and Quality Control Orders (QCOs).
• Representation in refund-related litigation and securing interest on delayed refunds.
• Representation against levy or validity, quantification, and other similar issues relating to anti-dumping duties and other similar levies.
• Assistance in Filing Reply to Show Cause Notices, Appeals, Writs, Special Leave Petitions before various courts in India with respect to direct and indirect tax matters.
• Representation before tax authorities and appellate forums in direct and indirect tax matters.
• Representation before High Courts / Supreme Court (both directly and through Senior Counsels).
• Audit and audit related support, handholding clients through DRI (Directorate General of GST Intelligence) and DGGSTI. (Directorate General of GST Intelligence) investigations, search and seizure exercises, identifying potential assessment and audit issues and providing support in matters related to justification of business models, valuation models.
• End to end litigation strategy including expediting cases under the legacy tax laws and amnesty schemes.

Tax and Regulatory Policy Support

• Representation before DGFT, CBIC, RBI, BIS, and DPIIT on tax and trade policies and other compliance matters.
• Representation before Policy Relaxation Committees and Development Commissioners for policies relating to FTP, SEZ and FTWZ and EOUs.

We bring together legal expertise, commercial awareness, and technical tax depth to deliver actionable and forward-looking solutions. Whether supporting a complex international transaction, navigating regulatory changes, or resolving a tax dispute, our Tax team provides advice that is clear, compliant, and aligned with our clients’ long-term goals.