International Taxation

This practice covers:

  • Non-resident taxability: determining what income is taxable in India and what falls outside its scope

  • DTAA interpretation: analysing applicable treaty provisions and their interplay with domestic law

  • TDS on foreign payments: advising on withholding obligations under Section 195 and relevant treaty exemptions

  • PE analysis: examining whether a foreign entity's presence constitutes a Permanent Establishment under domestic law or treaty

  • Cross-border transaction advisory: reviewing and advising on the tax dimensions of international transactions and structures