4i Advisory can assist you by providing holistic support from tax planning to implementation.
Tax Policy and strategy
- Evaluating current tax policy and advising on strategies to remain compliant with local laws and regulations
Inbound investments
- Evaluating entry strategies in India, including advising of entity structures, e.g. a company or limited Liability Partnership (LLP)
- Evaluating different modes of finance, keeping in mind commercial objectives, i.e. equity, debt (local vs. external commercial borrowing), hybrid instruments
- Reviewing contractual arrangements and highlighting tax-related consequences
- Advising on impact of taxation on repatriation, e.g. dividends or buyback of shares
- Evaluating exit options and strategies from the standpoint of tax
Outbound investments
- Strategizing outbound investments from India, bearing in mind Indian and overseas regulations
- Analyzing Place of Effective Management (POEM) rules to advice on tax residential status of foreign companies in India
- Advising on eligibility and quantum of foreign tax credits that can be claimed in India for overseas businesses
Permanent Establishment (PE) analysis
- Evaluating PE exposure of foreign companies doing business in India under related Double Taxation Avoidance Agreements (Tax Treaties) in different operating models, e.g. branches, project offices, and deputation of personnel and agencies
- Advising Indian MNCs on their potential PE exposure in foreign jurisdictions for their overseas businesses.
- Advising on the impact of the BEPS Action Plan 7 on Artificial Avoidance of PE on existing structures
- Advising on profits attributable to PE and resultant tax-related consequences
Optimization of Effective tax rate
- Advising on tax incentives and holidays available under tax laws, including start-ups
- Advising on dividend distribution tax cost savings
- Advising on realigning operating models to optimize taxes
- Reviewing Withholding Tax positions, including on cross-border transactions
Restructuring and reorganization of business
- Advising on consolidation or simplification of corporate structures
- Advising on unlocking cash traps
- Advising on internal reorganization or external acquisitions, mergers, etc.
- Advising on tax due diligence from the buy or sell side
Ongoing services
- Assisting in one-time tax registrations, i.e. Permanent Account Number (PAN) and Tax Deduction Account Number (TAN)
- Assisting in compliance with quarterly Advance Tax and Withholding Tax
- Assisting in annual tax return filings and tax positions to be adopted
- Assisting in reporting of Foreign Liabilities and Assets (FLA)
- Assisting in reporting of Specified Financial Transaction (SFT)
Impact Analysis
- BEPS measures – Equalization levy, Patent Box, interest deduction limitation, significant economic presence, etc.
- Income Computation and Disclosure standards (ICDS)
- Minimum Alternate Tax (MAT) adjustments for Indian-Accounting Standard (Ind-AS)- compliant companies
Representation services before Indian revenue authorities
- Assisting in obtaining nil or lower deduction tax certificates
- Assisting in obtaining No Objection and tax clearance certificates
- Providing audit-related support (Income Tax- and Withholding Tax-related)
- Providing post-audit-related support (rectification, penalty, stay, refund proceedings)
- Providing support on survey, search, seizure and prosecution proceedings
- Handling litigation matters and representing before tax authorities