Business Transaction Advisory
Development agreement
Assisted a company engaged in precast business with its development and co-operation agreement with a German company.
Share rewards
Assisted a software technology service company in evaluating options for rewarding contributors through offering shares.
IPR transaction
Advised Singapore based financial services group in structuring its inbound business model.
Start-up tax deduction
Assisted a technology company in evaluation of eligibility to claim start-up related tax deduction.
Co-operative bank merger
Assisted in identifying intangibles to be recorded pursuant to merger to enable tax break.
MFN analysis
Assisted a pharma company in evaluating eligibility to claim MFN benefit under treaties on transactions with overseas parties.
Disputed compensation
Assisted an Indian conglomerate in evaluating tax implications of compensation under a disputed agreement.
Offer for sale
Assisted an Indian company in evaluating tax implications of sale of shares in an offer for sale.
SEZ unit transfer
Assisted in transfer of a SEZ unit within the corporate group to eliminate redundant entity.
Escrow arrangement
Assisted a company in evaluation of tax implications of sale of shares held under escrow.
Tax Risk Assessment
Management fee
Feasibility analysis of charging management fee by Singapore parent to Indian subsidiary.
Cross border ESOP
Advised on tax and regulatory implications of a cross-border ESOP scheme.
Software payment taxability
Assisted in evaluating taxability of revenue received by a US entity from its Indian customers.
Transfer of distribution rights
Assisted a Pharma distributor in evaluating tax implications for transfer of its distribution rights.
Income taxability for NRI settled trust
Assisted an India trust settled by a NRI in evaluating tax implications of its investment income.
Angel tax
Assisted a technology company in building arguments to defend angel tax adjustment in tax assessment.
POEM analysis
Assisted an India HQ group in evaluation of POEM for its overseas subsidiary.
PE Evaluation
Assisted in evaluating whether the Indian operations constitute a PE of a US based entity.
PE taxation
Assisted a German group in evaluating tax implications of its PE in India.
BEPS Pillar 2
Assisted a French MNC group having presence in 30 countries in BEPS Pillar 2 impact analysis.
Promoter Advisory
Sale of listed shares
Assisted a New Zealand tax resident in evaluating Income-tax implications of sale of Indian listed shares.
Stock options
Assisted promoter of an e-commerce company in evaluating tax implications of ESOPs received partly as resident and partly as NR.
Relocation back to India
Assisted an HNI in planning his relocation back to India after spending 20 years in USA.
Offshore family office
Assisted a Pune based HNI in relocating to Singapore and setting up a family office.
Onshore trust set-up
Assisted a non-resident in settling a trust in India for the benefit of resident individuals.
Externalization
Transition of USA company shares held by an Indian resident to an overseas trust structure.
Corporate Structuring
Business division amongst partners
Assisted a real estate group in division of its business properties amongst partners.
Subsidiary set-up
Assisted an Indian company in setting up operating subsidiary in Kenya and evaluation of cash extraction modes.
Overseas Investments
Assisted an Indian NBFC in establishing a Singapore company for overseas investments.
Promoter rejig
Assisted a UX design company in redistribution of shares amongst promoters prior to a divestment transaction.
Outbound structuring
Assisted an Indian manufacturing company in setting up its operations in USA.
Hold Co. setup
Assisted a group in evaluating India tax & regulatory implications of creating an overseas holding company.
Subsidiarization
Assisted group engaged in insurance business in subsidiarization of one of the group company under the flagship company.
Global restructuring
Assisted an aviation group in evaluating India tax & regulatory implications of its global restructuring.
NBFC Consolidation
Assisted a group in consolidation of multiple NBFCs into one
Windmill undertaking
Assisted a Pune based group in structuring transfer of windmill undertaking without impact tax deduction.
Mergers and Acquisitions
Divestment (Deal size ~450crs.)
Assisted Pune based technology company in its divestment to a Blackstone backed listed company.
Divestment (Deal size ~150crs.)
Assisted Pune based wealth management firm in its divestment by way of business and share transfer.
Merger (4 entities)
Assisted Bangalore based financial business in merger of its acquired group entities into parent company.
Business transfer
Assisted a spa chain in transfer of its business by way of slump sale.
Secondary exit & Externalization
Assisted a Mumbai based consultancy company in externalisation along-with exit of one of its promoters.
Fund raise (Fund raise ~100crs.)
Assisted fintech group in structuring their fund raise from a Mauritian investor.
Business transfer
Assisted an USA and India based software development company for India business transfer as a part of global divestment.
IPR sale (Deal size ~USD 1mn)
Assisted technology company in transferring its IPRs to a US based corporation.
Global Transfer Pricing
Middle East based MNC group in
Assisted in implementation of TP principles for UAE entities.
Indian vaccine manufacturer
Assisted in determining arm’s length commission rate for its US subsidiary.
Auto component manufacturer in India and Europe
Assisted in formulating TP policy for interest and corporate guarantee.
European arm of Indian listed auto component
Assisted in three tier documentation (Local file and Master file).
US watch manufacturing MNC
Assisted in determination of arm’s length royalty rate for technology and trademark.
Indian arm of Japanese auto component manufacturer
Assisted in determining arm’s length royalty rate.
Indian technology company having presence in US, Europe
Assisted in streamlining operational TP structure.
German auto component manufacturing group
Assisted in benchmarking of intra group services transaction.
Swiss MNC
Assisted in determination of arm’s length interest rate for ECB.
Indian listed Technology company
Assisted in determination of arm’s length interest rate for outbound loans.
Indian liquor manufacturer
Assisted in formulating distribution TP policy for its Singapore subsidiary.
Coal distributor operating in Singapore
Assisted in benchmarking imports.
Singaporean arm of Japanese steel giant
Assisted in benchmarking and preparation of local file.
Indian pharma manufacturer
Assisted in setting TP policy for US distributor entity.
German arm of US Technology company
Assisted in determining arm’s length mark-up.
Singaporean arm of Luxemburg plasticisers manufacturer
Assisted in benchmarking and preparation of local file.
French Technology group
Assisted in preparation of local file for its European subsidiary.
Dutch MNC
Assisted in preparation of local file for its subsidiaries operating in APAC region.
Singapore based fertilizer distributor
Assisted in preparation of local file.
India based Specialty chemicals
Assisted in formulating transfer pricing policy for transactions with USA subsidiary.
Development agreement
Assisted a company engaged in precast business with its development and co-operation agreement with a German company.
Share rewards
Assisted a software technology service company in evaluating options for rewarding contributors through offering shares.
IPR transaction
Advised Singapore based financial services group in structuring its inbound business model.