Our cross-border transactional tax team has extensive experience in navigating the contours of deal-specific domestic and cross-border tax-advisory. Our innovative tax and structuring advice are at the core of our corporate practise. We are known for our special-situation tax expertise and have worked with sovereign wealth funds and investors for structuring complex transactions and developing unique models, informed by our strong research base and experience in carrying through a deal from start to finish.

The role of a tax advisor has generally been assumed by accounting firms, but each tax position needs to be validated under law. In our prior dealings, we have seen the lack of tax-enabled advisory as a huge handicap in sophisticated transactions, especially in the Indian context. In many cases, our understanding of the multi-jurisdictional tax laws coupled with a market-sounding approach has often helped in breaking deadlocks (or assisted in taking critical commercial calls) necessary to consummate transactions in India.

Our cross-border transactional tax services include:

• Recommendations on choice of jurisdiction from a regulatory and tax-optimisation perspective.
• Assessment of monetisation avenues and intended tax treatment, including through funds, InvITs or listing.
• Deciphering the most tax optimal structure for yield generating assets.
• Assessing tax implications on income/revenue flows for related parties.
• Structuring cross-border mergers and acquisitions.
• Restructuring of investments.
• India entry and exit strategies.
• Advising on transnational joint ventures and collaborations.
• Analysis of relating to treaty interpretation such as, characterization of income and permanent establishment concerns.