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International Tax

International Taxation & Transfer Pricing

DTAA relief, 15CA/15CB certifications, transfer pricing documentation and NRI taxation - for businesses and individuals with cross-border income.

Cross-border payments, foreign subsidiaries and NRI income all trigger overlapping Indian and treaty rules. We structure transactions to claim treaty relief correctly, certify remittances, and maintain transfer pricing documentation that stands up to scrutiny.

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DTAA Advisory
Double Taxation Avoidance Agreement analysis to reduce withholding tax on cross-border payments including dividends, royalties, fees for technical services and salary.
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Common DTAA Scenarios
  • Software services to clients in USA, UK or Singapore, DTAA may reduce TDS from 20% to 10% or lower
  • Salary of employees deputed abroad
  • Dividend from foreign subsidiaries
  • Royalty and technical service fees to non-residents
Documents Needed
  • Tax Residency Certificate from foreign country
  • Form 10F declaration
  • No Permanent Establishment declaration
  • Invoice and contract copy
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GCC Setup Advisory, SEZ vs STPI vs DTA
Strategic advisory for Global Capability Centres choosing between SEZ, STPI and non-STPI operating frameworks based on tax profile, compliance cost and operational needs.
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Framework Comparison
  • SEZ: Tax holiday under IT Act 2025, GST zero-rating on services, duty-free imports, strict compliance with Development Commissioner
  • STPI: Customs duty exemption, simpler compliance, SOFTEX and SERF filing obligations
  • Non-STPI (DTA): Simpler setup, standard GST and income tax, no export compliance overhead
Our Advisory Covers
  • Comparative tax and compliance cost analysis across structures
  • FEMA implications of each model
  • Transfer pricing policy for GCC to parent billing
  • EDPMS, APR and MPR obligations for chosen structure
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Transfer Pricing
Transfer pricing documentation, benchmarking studies and Form 3CEB certification for international and domestic related party transactions.
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Applicability
  • International transactions with associated enterprises above Rs.1 crore
  • Specified domestic transactions above Rs.20 crore
Deliverables
  • Transfer pricing study with benchmarking analysis
  • Selection and application of most appropriate method
  • Form 3CEB certification by a Chartered Accountant
  • Documentation maintained as per Rule 10D
Form 3CEB deadline: 31 October

Frequently Asked Questions

When do I need Form 15CB from a CA?

For most taxable foreign remittances above Rs.5 lakh in a year, Form 15CB certification of taxability and DTAA rate precedes the 15CA filing. We turn these around quickly for recurring remitters.

How does DTAA reduce my tax?

Tax treaties cap Indian withholding on royalties, fees for technical services, interest and dividends - often below domestic rates - and give credit for foreign taxes. Claiming relief needs a Tax Residency Certificate and Form 10F.

When is transfer pricing documentation mandatory?

Any international transaction with an associated enterprise triggers Form 3CEB certification, with detailed documentation required once transactions cross Rs.1 crore (and Master File thresholds at group level).

Discuss your requirement

Talk directly to CA CS CMA Krupanand Bammidi - no call centers, no juniors on first calls.

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