Picking A Regime On The Headline Rate
22% looks better than 30% until you count the deductions surrendered, the MAT credit stranded and the incentives forgone. The comparison has to run over several years, on your own numbers.
Corporate Tax Advisory In India
A new Income-tax Act, renumbered concessional regimes and a reworked MAT. Our corporate tax team tells you which regime you should be in, what your effective rate actually is, and where your current position will not survive scrutiny.
Plan The Tax, Not Just The Return!
What Is Corporate Tax Advisory?
Corporate tax advisory is the work that happens before the return to ensure compliance with complex tax regulations. It decides which tax regime your company sits in, how a transaction is structured, what rate applies to each stream of income, and what documentation will hold up when the assessing officer asks.
Filing is the output. Advisory is where the money is made or lost. A regime election made without a five-year view, a group restructuring signed before anyone modelled the tax, a related-party price set by convenience rather than benchmarking: each of these costs far more than the fee for getting it right at the start.
At DSRV and Co LLP we have spent more than 30 years advising Indian companies, subsidiaries of foreign groups and promoter-led businesses. We look at your structure first, then the compliance calendar, then the savings. That order matters. A clever tax idea sitting on a weak structure falls apart at assessment.
Who Needs Corporate Tax Advisory In India
1. Companies Choosing Or Reviewing A Tax Regime
The concessional regime is not automatically the better deal. Whether it beats the normal regime depends on the deductions you are giving up, your MAT credit position, your loss carry-forward and how long you expect the current profit profile to last. The election has conditions and a filing deadline, and reversing it is not a casual decision.
2. Indian Subsidiaries Of Foreign Groups
Management fees, royalty, cost allocations, interest on group loans and shared services all sit at the intersection of corporate tax, transfer pricing and withholding. Each one needs a defensible commercial rationale and documentation created at the time, not later.
3. Groups Doing A Restructuring, Merger Or Buyout
Amalgamation, demerger, slump sale, share transfer and buyback all have very different tax outcomes. Loss carry-forward, MAT credit, capital gains treatment and stamp duty move with the structure you pick, and the decision cannot be fixed after signing.
4. Promoter-Led And Family Businesses
Remuneration versus dividend, group loans, related-party rent, holding company layers and succession planning need to work at both the company level and the promoter level. Advice that optimises only one side usually creates a problem on the other.
5. Companies Under Notice Or Audit
Faceless assessment, reassessment, disallowance of expenses, transfer pricing adjustments and TDS defaults all need a position built on the record. The strength of your file is set long before the notice arrives.
Our Corporate Tax Advisory Services
Advisory And Planning
- Tax regime selection and modelling, including the option filing and the deductions you trade away
- Effective tax rate reviews, with surcharge, cess and marginal relief factored in properly
- Transaction and business model structuring, reviewed before contracts are signed
- Holding structure, funding and thin capitalisation advice, including interest deductibility limits
- Dividend, buyback and profit repatriation planning at both company and shareholder level
- Capital gains and business reorganisation advice across mergers, demergers and slump sales
- Loss and unabsorbed depreciation carry-forward planning, including change-of-shareholding traps
- Withholding tax advisory on domestic and cross-border payments
- GAAR and substance reviews before a structure is implemented rather than after
- Permanent establishment, POEM and cross-border exposure for groups with overseas links
Compliance Management
- Advance tax computation and quarterly review, so there are no year-end surprises
- Corporate return filing, tax audit and the prescribed reports and certifications
- TDS and TCS compliance, returns, corrections and lower-deduction certificates
- Transfer pricing documentation, the accountant's report, master file and country-by-country reporting where thresholds apply
- Regime option forms and other elections filed within their deadlines
- A compliance calendar you can actually see, mapped to your entity and your year
Litigation And Representation
- Response drafting for faceless assessment, scrutiny and reassessment notices
- Representation before the assessing officer, the Dispute Resolution Panel, CIT(A) and the tribunals
- Penalty and prosecution defence, and rectification and refund follow-through are essential in tax matters.
- Advance rulings, safe harbour and advance pricing agreement support
Corporate Tax In India: What Changed Recently
The rulebook moved, and it moved fast. If your tax working files, board notes, and internal templates still quote the old sections, they need a clean-up for tax compliance before the next filing cycle.
The Income-tax Act, 2025 replaced the six-decade-old 1961 Act from 1 April 2026, and the Income-tax Rules, 2026 were notified in March 2026. The substance of corporate taxation largely survived, but section numbers, forms and timelines were reorganised. The concessional 22% regime for domestic companies and the 15% regime for new manufacturing companies now sit in the new Act's numbering rather than the familiar 115BAA and 115BAB, and the corresponding option forms were redesigned.
On rates, the headline position for a domestic company is 25% where turnover in the relevant earlier year does not cross ₹400 crore and the company stays in the normal regime, and 30% otherwise, with surcharge of 7% or 12% depending on total income, plus 4% health and education cess. A domestic company in the concessional regime pays 22% with a flat 10% surcharge. New manufacturing companies meeting the conditions are at 15%. Foreign companies are taxed at 35%, with surcharge of 2% or 5%. Marginal relief applies across the board, and it is routinely missed in in-house computations related to tax compliance.
Minimum Alternate Tax is the change most finance teams have underestimated. The Budget for 2026-27 moved MAT toward being a final tax, with the rate reduced to 14% from 15%, no fresh credit accumulation from 1 April 2026, and brought-forward credit accumulated up to 31 March 2026 usable only in the new regime and capped at one-fourth of the liability in a year. Companies sitting on a large MAT credit balance need to model this before deciding which regime to be in. Companies in the concessional regimes remain outside MAT, and non-residents taxed on a presumptive basis are exempt.
Buyback economics also changed. Buyback proceeds are taxed as capital gains for all shareholders, with an additional buyback tax that takes the effective burden to roughly 22% for corporate promoters and 30% for non-corporate promoters. Any distribution plan built on the older buyback treatment should be re-run.
Above all of this sit GAAR, the OECD's BEPS measures and the Multilateral Instrument. Large groups also have to track how Pillar Two minimum tax rules being adopted in other countries change the effective rate on their Indian profits, even where Indian law itself does not impose the top-up.
Where Companies Lose Money On Corporate Tax
Missing The Option Deadline
Concessional regimes require an election filed on or before the return due date. Miss it, and the higher rate applies for that year regardless of eligibility, impacting your overall tax compliance.
Treating Related-Party Pricing As An Internal Matter
Management fees and cost allocations with no benchmarking and no evidence of benefit received are the first thing an officer disallows, and the adjustment usually carries penalty exposure.
Structuring First, Modelling Later
By the time a share purchase agreement or scheme of arrangement is signed, the tax outcome is fixed. Reviewing it afterwards only tells you what it cost.
Ignoring Withholding On Ordinary Payments
TDS defaults on professional fees, rent, contractor payments, and cross-border remittances cause disallowance of the expense plus interest and penalty, on amounts far larger than the tax matters involved.
Building Substance-Free Structures
Where GAAR applies, an arrangement that exists only for the tax benefit can be set aside no matter how clean the paperwork looks.
How DSRV India Helps With Corporate Tax
Regime And Effective Rate Modelling
We run both regimes on your actual numbers over a multi-year horizon, including MAT credit, losses and incentives, and give you a recommendation you can take to the board.
Transaction Structuring
We review the deal before it is signed to address any potential indirect tax issues. Funding, entity choice, and contract wording all move the final tax number, and all of them are cheaper to change early to ensure compliance with tax laws.
Compliance Under Control
Advance tax, TDS, audit reports, certifications and elections, tracked against a calendar with owners and dates, so nothing lapses quietly.
Transfer Pricing Support
Benchmarking studies, the accountant's report, master file and country-by-country reporting, safe harbour and advance pricing agreement advice, and representation when an adjustment is proposed are key compliance services.
Group And Cross-Border Advisory
Holding structure, repatriation, treaty positions, permanent establishment risk and foreign tax credits for companies with income or ownership outside India.
Assessment And Litigation
Faceless assessment responses built on the record, plus representation before the assessing officer, the Dispute Resolution Panel, CIT(A), tribunals and higher courts.
Health Checks And Regular Updates
A periodic tax health check on positions already taken, and short plain-language notes on amendments and rulings that affect your business rather than every change in the gazette.
Why Choose DSRV India For Corporate Tax Advisory?
Three decades of work across direct tax, international tax, transfer pricing, FEMA and GST means one team can see a transaction from every angle instead of four advisors emailing each other. Most of what your notice says, we have already argued with the tax authorities.
Our clients range from promoter-led Indian companies to Indian subsidiaries of foreign groups, so tax consultant advice is built for your facts and not lifted from a template. You get a clear position, the risk stated honestly, and the compliance steps in order. That is why organisations stay with us for decades rather than a single filing season.
FAQs About Corporate Tax Advisory In India
What does a corporate tax advisor actually do?
Advises on which tax regime to be in, structures transactions before they are signed, computes and reviews the effective tax rate, manages advance tax, TDS, audit and transfer pricing compliance, and defends positions in assessment and appeal.
What is the corporate tax rate in India?
A domestic company pays 25% where turnover in the relevant earlier year is within ₹400 crore and it stays in the normal regime, and 30% otherwise, plus surcharge and 4% cess, in compliance with tax laws. The concessional regime is 22% with a flat 10% surcharge, new manufacturing companies can be at 15%, and foreign companies are taxed at 35%.
Should my company move to the concessional regime?
Only after modelling it. You give up specified deductions and incentives, and any unused MAT credit becomes usable only under the conditions now in force. For a company with heavy incentives or a large credit balance, the normal regime can still win.
Has the Income-tax Act really changed?
Yes, we ensure compliance with tax and regulatory requirements. The Income-tax Act, 2025 applies from 1 April 2026, and the Income-tax Rules, 2026 were notified in March 2026, reflecting the latest tax laws. The corporate tax framework largely carried over, but sections, forms and timelines were renumbered and redesigned.
Is MAT still applicable?
Yes, for companies in the normal regime, but its role has changed. MAT has been moved toward a final tax at 14%, fresh credit no longer accumulates from 1 April 2026, and credit built up earlier can be set off only in the new regime, limited to one-fourth of the year's liability. Confirm the exact position for your tax year before computing.
Do small companies need corporate tax advisory?
Yes, and often more than large ones. Regime choice, related-party transactions, promoter remuneration and TDS compliance carry the same rules regardless of size, and a small company has less room to absorb a disallowance.
How is transfer pricing connected to corporate tax?
Any international transaction with an associated enterprise must be priced at arm's length, whatever the size of the company. An adjustment increases taxable income directly, which is why benchmarking and contemporaneous documentation are part of corporate tax planning rather than a separate exercise.
Can you help if we have already received a notice?
Yes. We review what is on the record, draft the response, and represent you through faceless assessment, the Dispute Resolution Panel, CIT(A) and the tribunals. Bring it to us early: the first reply usually shapes the rest of the case.
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