International Taxation & Transfer Pricing
As the world becomes a global village, there is a surge in cross border transactions. More and more companies are willing to set up their business practices in India. Thus, there is a need to implement strategies in order to address various tax opportunities in order to achieve growth.
UJA’s tax professionals assist clients with setting up of their business in India. Apart from this, we provide the most efficient tax holding structure to meet the business objectives, advisory in relation to cross border transactions in order to optimize taxes, analyze the applicability of withholding taxes in relation to cross border payments, financial accounting, tax compliances etc. UJA also provides services in the areas of structuring Cross-Border Mergers and Acquisitions, Financing Transactions, Investment restructuring, advise on JVs and Collaborations, understanding and
interpretation of Bilateral Agreements and Treaties.
Analysis of tax treaties and bilateral agreements
UJA has a complete understanding of tax treaties between countries and bilateral agreements. These help to map the business plan for Indian companies going global or international companies coming to India.
Cross Border Taxation
UJA offers advice on cross border taxation that includes Place of Effective Management (POEM), Income Computation and Disclosure Standards (ICDS), General Anti Avoidance Rules (GAAR), Base Erosion and Profit Shifting (BEPS).
UJA provides services in the areas of structuring Cross-Border Mergers and Acquisitions, Financing Transactions, Investment restructuring, advise on JVs and Collaborations, understanding and interpretation of bilateral Agreements and Treaties
Advice on cross border transactions, double tax treaties and foreign tax systems/implications, tax efficient structuring of cross border transactions, improvement/effectiveness of the cross border ‘Supply Chain’ process, International tax dispute resolution.
Expatriate tax matters, right from planning a compensation package to the filing of the expatriate employee tax return.
One of the core strengths of UJA is Transfer Pricing. UJA develops and executes viable Transfer Pricing Policies, Compilation and Documentation.
Services include compliance, documentation, support in developing and implementing transfer pricing policies, new transfer pricing structures, aligning existing transfer pricing policies. Support and advice on BEPS readiness and implementation and on the applicability of master file and country by country (CbC) reporting requirements, functional and comparability analysis, advise on transfer pricing risk analysis and alignment with group’s master file, transfer pricing analysis of financial transactions and transactions involving intangibles including license and transfer of intellectual property,
assistance in obtaining report in Form 3CEB, assistance in Due diligence report from transfer pricing perspective, assistance in preparing global transfer pricing policy document, Advance Pricing Agreements (APA), Mutual agreement procedures (MAP), Safe Harbour applications and transfer proceedings.