International Taxation

The tax result of a cross-border group is mostly decided before the second entity is formed, not at year-end. Where the holding company sits, how it is funded, and whether the operating companies pay royalties or management charges all flow into the return that gets filed. We set the structure against the whole group before anything is registered, then keep it defensible as the group adds entities.

Running each country through a separate local adviser produces returns that contradict each other — profits described one way in the US return and another in the Indian one. We hold the whole file, so the group reports a single consistent position across every jurisdiction.

A treaty can halve a withholding tax or remove it entirely, but only if the recipient is genuinely resident where it claims to be and the income matches the right article. We map the treaty network that applies to your flows, test entitlement against limitation-on-benefits and principal purpose tests, and document the position before the payment is made rather than during an audit.

Foreign tax credits and double-taxation relief are mechanical only after the underlying positions agree. We reconcile credits across the group so the same profit is not taxed twice and the credit is claimed in the right country in the right order.

Related-party margins are now the most audited area in every country we serve. We benchmark the dealings, prepare the three-tier documentation, and keep the same margin story consistent across each local return. See our Transfer Pricing service for the full method.

Expatriates, NRIs and people relocating between the US, Canada, India and the UAE each face residency tie-breakers, exit taxes and split-year rules. We set residency and arrival dates deliberately, plan the timing of income, and prepare the home and host returns so the individual is not taxed on the same income twice.

For EB-5 and investor programmes, we prepare the source-of-funds narrative and supporting documentation that the filing requires, working alongside immigration counsel.

A written structure note before formation, a treaty and credit plan, a transfer pricing position that holds across the group, and the filings themselves. The deliverable is a defensible file, not a set of disconnected returns.