Intellectual Property Registration & Protection Advisory for Foreign Companies in India

International Tax Planning and Advisory

International Tax Advisory for International Clients

A2 Consultants offers specialized International Tax Advisory services tailored for foreign investors, multinational corporations (MNCs), NRIs, and global entrepreneurs doing business in or with India. As international tax frameworks evolve—driven by OECD guidelines, BEPS (Base Erosion and Profit Shifting), and multilateral tax treaties—navigating cross-border taxation has become a top strategic priority.

We help you structure your global business efficiently, comply with Indian and international tax regulations, and mitigate double taxation, permanent establishment (PE) risks, and transfer pricing disputes.

Our Core International Tax Services

Cross-Border Tax Planning & Structuring

Strategic advisory on designing and implementing tax-efficient cross-border business models:

• Structuring foreign direct investments (FDI) into India
• Advisory on capital gains tax for foreign shareholders
• Utilizing Double Taxation Avoidance Agreements (DTAAs) effectively
• Optimizing royalty, interest, dividend repatriation routes
• Planning for tax-neutral inbound and outbound investments
• Managing withholding tax implications on foreign remittances

Global Business Structuring & Restructuring

We design scalable global holding structures that align with your long-term tax and operational objectives:

• Incorporating tax-optimized holding companies
• Setting up foreign subsidiaries or LLPs in India
• Cross-border mergers, demergers, and joint ventures
• Exit strategies including capital repatriation and divestment
• Corporate reorganizations to align with global tax efficiency goals

Permanent Establishment (PE) Risk Assessment

Avoid unintended tax exposure in India due to PE creation:

• PE determination under Indian tax law and relevant DTAA clauses
• Risk analysis for liaison offices, project offices, dependent agents
• Tax impact analysis and dispute mitigation strategies
• Conversion of PE exposure into compliant subsidiary structures

Transfer Pricing Compliance & Advisory

We ensure full compliance with India’s evolving transfer pricing laws:

• Functional analysis and benchmarking studies
• Drafting of transfer pricing documentation (TPD)
• Transfer pricing audit defense and litigation support
• Advisory on intercompany transactions, royalty payments, and cost-sharing arrangements

International Tax Compliance & Reporting

Stay globally compliant with our full-spectrum reporting services:

• Income tax return filing for foreign companies and NRIs
• Form 15CA/15CB advisory for foreign remittances
• Reporting under Equalisation Levy, GAAR, and BEPS regulations
• FATCA, CRS, and OECD country-by-country reporting (CbCR) assistance

 DTAA & Treaty Benefit Advisory

Navigate over 90 DTAAs signed by India to avoid double taxation:

• Residency determination and TRC (Tax Residency Certificate) assistance
• Treaty relief eligibility assessment
• Application of Most Favoured Nation (MFN) clauses and beneficial rates
• Avoidance of treaty abuse and compliance with Principal Purpose Test (PPT) under MLI

Who We Serve

• Multinational corporations (MNCs) expanding into India
• Non-resident Indians (NRIs) with global and Indian income
• Foreign startups, VC/PE firms investing in India
• Exporters/importers involved in global trade with India
• Tech companies with remote or outsourced teams in India
• Foreign subsidiaries, branch offices, and liaison offices

Contact us today at [email protected] or visit our website to schedule a Free consultation.

Transfer Pricing Services

Transfer Pricing Services for International Clients in India

At A2 Consultants, we deliver comprehensive Transfer Pricing advisory, documentation, and risk mitigation services tailored for foreign companies, MNCs, and international investors operating in India. With increased scrutiny from Indian tax authorities and global coordination through OECD BEPS Action Plans, ensuring arm’s length pricing for your related party transactions is critical to compliance and profit protection.

Our experts combine regulatory insight, economic analysis, and global tax planning experience to help you structure intercompany transactions, optimize compliance, and avoid disputes.

Our Transfer Pricing Services Include:

1. Transfer Pricing Documentation & Compliance

We ensure full compliance with Indian and global reporting obligations:

• Preparation of Transfer Pricing Study Reports in line with Indian Income Tax Act
• Benchmarking analysis using reliable databases to establish arm’s length pricing
• Local File, Master File & CbC (Country-by-Country) reporting compliance
• Tailored documentation to meet Indian TP rules and OECD guidelines

2. Transfer Pricing Advisory & Risk Assessment

Strategic guidance to align global business operations and tax objectives:

• Functional and economic analysis for intra-group transactions
• Risk-based review of transfer pricing exposure
• Designing defensible pricing policies for IP licensing, services, financing, etc.
• Audit support and representation before Indian tax authorities

3. Advance Pricing Agreements (APA) & Dispute Resolution

Minimize future tax uncertainty with long-term TP solutions:

• End-to-end support for APA filing with Indian tax authorities (Unilateral, Bilateral & Multilateral)
• Assistance with Mutual Agreement Procedures (MAPs) under DTAAs
• Dispute resolution for TP assessments or adjustments
• Post-agreement compliance and annual reporting

Who We Serve

• Multinational Companies (MNCs)
• Global Startups and Investors
• Foreign Subsidiaries in India
• E-commerce, SaaS, Manufacturing & Financial Services Companies

Why Choose A2 Consultants

• Transfer pricing specialists with experience in Big advisory
• Customized solutions aligned to your industry, entity structure, and jurisdictions
• Up to date with evolving rules under Indian TP law, OECD BEPS, and global reporting trends
• AI-enhanced approach for compliance automation and risk detection

IF you are looking for :

• Transfer pricing services India
• Transfer pricing documentation India
• Transfer pricing advisory India
• CbC reporting consultants India
• Master File Local File compliance India
• Transfer pricing risk assessment
• Advance Pricing Agreement (APA) India
• Mutual Agreement Procedure (MAP) India
• Related party transactions India
• Arm’s length pricing India

Contact us today at [email protected] or visit us to schedule a Free consultation.

GloBE & Digital Transfer Pricing Services

GloBE & Digital Transfer Pricing Services 

Global Minimum Tax (Pillar Two) & Top-Up Tax Advisory

As OECD's Pillar Two – Global Minimum Tax (GloBE) rules come into effect, multinational companies with operations in India must navigate complex global tax reforms. At A2 Consultants, we provide comprehensive GloBE compliance services and top-up tax impact analysis to help you meet the 15% minimum effective tax rate (ETR) threshold across jurisdictions.

Our GloBE & Top-Up Tax Planning Services Include:

• GloBE Effective Tax Rate (ETR) calculation by jurisdiction
• Identification of covered taxes, adjustments, and safe harbors
• Top-Up Tax computation and jurisdictional blending advisory
• Assistance with local and global Pillar Two reporting obligations
• Structuring advice to minimize top-up tax exposure
• Country-by-country analysis for GloBE modeling
• Advisory on Qualified Domestic Minimum Top-Up Tax (QDMTT) rules in India and other countries
• Strategic restructuring to align with BEPS 2.0 norms

Transfer Pricing Advisory for Digital & E-Commerce Businesses

With the rise of digital services, platform economies, and borderless tech delivery, tax authorities globally—especially in India—are focusing on transfer pricing risk for the digital economy. At A2 Consultants, we help you structure and document your intercompany digital transactions in line with Indian Income Tax Act and OECD’s BEPS guidance.

Our Transfer Pricing Services for the Digital Economy Include:

• TP risk assessment for SaaS, marketplaces, cloud platforms, gaming, fintech, and e-commerce models
• Functional analysis of IP ownership, user-based value creation, and data monetization
• Benchmarking and arm’s length pricing for royalty, licensing, and intangibles
• Digital permanent establishment (PE) assessment and profit attribution
• Preparation of Master File, Local File, and CbC reporting
• Advisory on Equalisation Levy / Digital Services Tax (DST) applicability in India
• Transfer pricing planning for new-age business models (AI, Web3, digital advertising, etc.)
• APA & MAP advisory for dispute prevention and resolution

Who We Serve

• Global SaaS & cloud companies entering India
• International e-commerce marketplaces with Indian sellers or buyers
• Fintechs, gaming startups, and media platforms with cross-border flows
• MNCs restructuring for Pillar Two compliance
• Tax departments preparing for CbCR, QDMTT & digital TP audits.

Contact us today at [email protected] or visit us to schedule a Free consultation.

Expatriate & International Individual Tax Services

At A2 Consultants, we provide comprehensive expatriate tax advisory and international individual tax planning services for foreign nationals working in India, returning NRIs, cross-border executives, and globally mobile professionals. Whether you're an individual relocating to India or a multinational company deploying international staff, we help ensure full income tax compliance, minimize double taxation, and create tax-efficient compensation strategies.

Our team of experts ensures smooth navigation of Indian tax laws, residency rules, DTAA provisions, and global disclosure obligations, with tailored support that integrates seamlessly with your global mobility program.

Core Areas of Expertise

1. Expat Tax Residency & Global Compliance

Understanding Indian tax residency and its global implications is crucial for accurate filing and liability assessment. We provide:

• Tax residency determination under Section 6 of the Indian Income Tax Act
• DTAA-based residency assessment and tie-breaker rule analysis
• Income tax return filing in India and advisory on host/home country reporting
• Compliance with FATCA/CRS reporting, foreign asset disclosures, and Schedule FA

2. International Compensation Structuring

Designing tax-optimized salary and benefits is key for globally mobile professionals. Our experts offer:

• Structuring of allowances (housing, relocation, education) and tax-exempt benefits
• Advisory on stock options (ESOPs, RSUs), deferred bonuses, and equity-linked compensation
• DTAA utilization for foreign income exemptions, credit mechanisms, and reduced tax rates

3. Social Security, Retirement & Exit Planning

We help manage global pension and social contributions with clarity on Indian rules:

• Totalization agreement analysis and social security coverage exemption (SSA eligibility)
• Tax planning for provident funds, NPS, and foreign pension contributions
• Exit tax planning for departing expatriates (India exit tax advisory)

4. NRI & Returning Indian Tax Services

Tailored solutions for non-resident Indians (NRIs) and returning residents include:

• RNOR and NRI status optimization
• Tax impact on foreign income, real estate sales, and capital gains
• Investment structuring in India and abroad for long-term tax efficiency

 Why Choose A2 Consultants for Expatriate Tax Services?

• In-depth understanding of India’s international tax laws
• Proven expertise with Big expatriate assignments
• AI-powered compliance tracking for dual tax obligations
• Personalized attention and zero-penalty compliance record

If you are looking for the below :

• Expatriate tax planning India
• NRI income tax advisor
• Tax residency rules India
• DTAA India benefits
• Tax filing for expats in India
• Global mobility tax compliance
• Foreign income tax return India
• Social security agreement India
• Taxation of stock options for expats India
• FATCA and foreign asset disclosure India
• Exit tax for expats India
• RNOR tax benefits India

Contact us today at [email protected] or visit us to schedule a Free consultation.

DTAA & International Tax Treaty Advisory Services

Avoid Double Taxation | Maximize Treaty Benefits | Ensure Global Tax Compliance

At A2 Consultants, we specialize in Double Taxation Avoidance Agreement (DTAA) advisory and international tax treaty planning for foreign companies, NRIs, expatriates, and cross-border professionals. With India’s extensive network of over 90 DTAAs, understanding and applying the right treaty provisions can significantly reduce your global tax burden while ensuring complete compliance with both Indian and international laws.

Our services are designed to help you avoid double taxation, optimize withholding tax, secure treaty benefits, and address Permanent Establishment (PE) risks—all while keeping your documentation audit-proof.

Key DTAA & Tax Treaty Services

1. DTAA Eligibility Analysis & Benefit Optimization

We assess your eligibility and help you claim the most advantageous treaty relief:

• Residency-based eligibility under the OECD model and UN model conventions
• Choosing the right method: Tax credit, exemption, or reduced rate
• Advisory on specific DTAA articles: royalties, dividends, interest, FTS (fees for technical services)

2. Documentation & Regulatory Support

Proper documentation is critical to claim DTAA relief. We help you with:

• Obtaining Certificate of Residence (COR) from foreign jurisdictions
• Preparing and submitting Form 10F, TRC, and self-declarations
• Ensuring full Rule 21AB and Form 15CB/15CA compliance for foreign remittances

3.  PE (Permanent Establishment) Risk Advisory

We guide foreign businesses on structuring operations to avoid unintended PE status in India:

• PE assessment under DTAA articles (fixed place, service PE, dependent agent PE)
• Structuring contracts, employee presence, and liaison/project offices
• Advisory on profit attribution, PE compliance, and PE disclosure requirements

4.  International Residency & Dual Taxation Solutions

We assist in complex residency situations:

• Dual tax residency analysis using tie-breaker rules
• Avoiding taxation on the same income in multiple jurisdictions
• Coordination with home country advisors for global tax strategy alignment

5.  Business Remittances & Withholding Tax (WHT) Advisory

We ensure optimal WHT strategies for inbound/outbound remittances:

• DTAA-based advisory on withholding tax rates on foreign payments
• Evaluation of FTS, interest, dividends, and royalty payments under treaties
• Certification under Form 15CB, tax gross-up, and DTAA disclosures in returns

6.  Treaty-Based Transfer Pricing & MAP/APA Support

Advanced treaty compliance for global corporations:

• Treaty impact on transfer pricing and related party transactions
• Assistance with Mutual Agreement Procedure (MAP) to resolve treaty disputes
• Support in Advance Pricing Agreements (APA) involving DTAA interpretations

 Why A2 Consultants for DTAA & Treaty Advisory?

• Decades of experience in international tax planning for foreign companies
• Trained professionals with practical treaty interpretation experience
• Zero-penalty record on foreign remittance tax filings
• End-to-end support from residency certificate to tax credit claim

IF you are looking for :

• DTAA benefits for NRIs
• Tax treaty advisory India
• Double taxation relief India
• Certificate of residence India
• Form 10F filing support India
• Tax residency rules India
• PE risk assessment India
• Withholding tax under DTAA India
• Royalty and interest taxation India
• DTAA with USA/UK/Singapore/Germany
• Mutual Agreement Procedure India
• APA and MAP services India
• Foreign remittance tax advisory India
• Avoiding double taxation India

Contact us today at [email protected] or visit us to schedule a Free consultation.