Advisory on DTAA, FEMA compliance, and expatriate taxation.
The landscape of global business has fundamentally shifted with the enactment of the Income-tax Act, 2025, and the sweeping overhaul of foreign exchange laws under the FEMA (Export and Import of Goods and Services) Regulations, 2026. Navigating international taxation requires more than basic compliance—it demands a strategic understanding of Source versus Residence taxation, the nuances of Permanent Establishment (PE), and strict adherence to global reporting standards.
We assist multinational corporations, returning NRIs, and expatriates in deciphering the complexities of cross-border tax implications. Our expertise spans the interpretation of Double Taxation Avoidance Agreements (DTAAs), managing Place of Effective Management (POEM) and General Anti-Avoidance Rules (GAAR) risks, and optimizing withholding tax protocols under the revamped statutory framework. We also guide foreign entities through the latest tax exemptions, such as those introduced for data center services and capital equipment provisioning.
Our dedicated FEMA desk provides robust advisory on inbound and outbound investments, including the recent liberalization permitting 100% FDI in the insurance sector. We streamline your compliance under the new unified FEMA trade framework—helping you transition seamlessly from legacy SOFTEX filings to the new single Export Declaration Form (EDF). For high-net-worth individuals and expatriates, we ensure watertight compliance with the Black Money Act, including strategic guidance on Schedule FA disclosures and leveraging the newly introduced FAST-DS 2026 amnesty scheme.
Unified Export ReportingThe cumbersome SOFTEX forms for software exports have been scrapped in favor of a single unified Export Declaration Form (EDF) under the 2026 FEMA updates.
Black Money Act RigorDisclosure of all foreign assets (including zero-balance accounts, RSUs, and fractional shares) in Schedule FA is mandatory for Resident and Ordinarily Resident (ROR) taxpayers, regardless of tax liability.
Residential StatusTax liability hinges largely on physical presence in India during the financial year. The law uses specific day-count thresholds to categorize an individual as a Resident and Ordinarily Resident (ROR), Resident but Not Ordinarily Resident (RNOR), or Non-Resident (NR).
A Double Taxation Avoidance Agreement lets you avoid being taxed twice on the same income across two countries, through credits or exemptions. We determine the relief available to you.
Often yes, where they have Indian income or specified assets. We assess and handle the compliance.
Compliance with the Foreign Exchange Management Act, which governs cross-border transactions, investments, and remittances. We guide you through the requirements.
A PE is a fixed place of business through which a foreign enterprise operates in India. If a PE is established—whether through a physical office, a construction site, or dependent agents—the profits attributable to that PE become taxable in India.
Yes. If your residential status is Resident and Ordinarily Resident (ROR), you must declare all foreign bank accounts, retirement funds, property, and equity (including ESOPs) in Schedule FA of your Indian tax return.
While holding a valid TRC from your home country is mandatory to claim DTAA benefits, it is not sufficient on its own. Tax authorities also evaluate the 'Beneficial Ownership' of the income and apply General Anti-Avoidance Rules (GAAR) to ensure the treaty is not being abused for tax evasion.
Yes, including the tax and FEMA aspects and the certifications that may be required.
Tell us a little about your requirement and our team will get back to you with the right guidance and a clear next step.
