Name: Your Trusted Financial Partner
Brand: DSRV India
Rating: 4.8 (1479 reviews)

Expert Guidance At Every Step

What Are International Taxation Services?

The moment your business earns money outside India, or a foreign company earns money from India, two tax systems start looking at the same income. International taxation services exist to handle that overlap.

In simple words, international taxation is the set of rules that decides which country can tax a transaction, at what tax rates, and how much credit you get for tax already paid somewhere else, often requiring guidance from international tax advisors. It pulls together the Income-tax Act, India's tax treaties, transfer pricing rules, FEMA, and GST on imports and exports for comprehensive advisory services.

At DSRV and Co LLP, we have spent more than 30 years helping Indian businesses, multinational companies, expatriates and NRIs deal with tax matters. We look at your structure first, then your compliance calendar, then the tax strategies for optimal savings. That order matters when consulting with tax professionals. A smart tax planning idea built on a weak structure usually falls apart at the assessment stage.

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Types Of International Taxation Work We Handle

Inbound: Foreign Money Coming Into India

When a foreign group sets up here, the first question is whether it creates a permanent establishment in India, which has significant implications for direct tax. A liaison office, a project site, a dependent agent, or even a long-staying employee can trigger one, and that changes everything about how much India can tax, impacting cross border transactions. We also advise on choosing the right entity (subsidiary, branch, liaison or project office), Place of Effective Management risk, profit repatriation, and how much tax to withhold on payments going out.

Outbound: Indian Businesses Going Global

For outbound plans, the tax bill depends on where you park the holding company, how you fund it, and how profits come home, necessitating effective tax planning services. We help with overseas structure options, FEMA and ODI reporting, taxation of dividends and interest received from abroad, and claiming foreign tax credits so the same profit is not taxed twice. Many companies lose credits simply because documentation was collected too late.

Related-Party Dealings: Transfer Pricing

If your Indian company deals with a group entity in another jurisdiction, the price must be at arm's length. We benchmark the transaction, pick the right method, prepare the documentation, and defend it if the tax officer disagrees.

Global Growth, Smart Taxation!

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What we do

Our international tax services

One cross-border transaction, two rulebooks. Our taxation services cover the direct tax and the GST side together, so the same payment is not treated one way for withholding and another way for place of supply.

International tax advisory

Cross-border transactions and business models reviewed before you sign, not after the notice lands.

Withholding tax opinions

Payments to non-residents, rate calls, and lower-deduction certificates under Section 197.

Tax treaty and DTAA benefit analysis

Treaty eligibility with the TRC, Form 10F and no-PE documentation that survives scrutiny.

Permanent establishment and POEM reviews

An honest read on your India exposure, and what to change if it is too high.

GST on import of goods and services

Reverse charge exposure mapped payment by payment, including foreign software and SaaS. New entities can start with GST registration in Gurgaon.

Place of supply and intermediary analysis in tax matters

Export contracts reviewed for the intermediary risk that turns zero-rated income taxable.

Expatriate and NRI taxation

Secondment structures, residency calls and special tax rates on NRI investments in India are key areas for international tax professionals.

Inbound and outbound structuring for effective tax planning services

Foreign investment into India, and Indian investment abroad with FEMA and ODI reporting.

Export refunds and LUT compliance

Zero-rated supply documentation, refund filing and follow-through on stuck claims.

Transaction structuring to protect input tax credit

Contract and billing flows arranged so credit is not lost somewhere in the chain.

Foreign tax credits and relief claims

Form 67, supporting certification and evidence collected while it still exists, is essential for tax authorities.

Incentives for exporters

Government schemes and benefits you are eligible for, identified and claimed on time.

Assessments, disputes and representation

Before the assessing officer, DRP, CIT(A), tribunals and higher courts, through our tax litigation services.

International Tax Compliance In India: What Changed Recently

The rulebook has moved, and it has moved fast.

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 core international tax and transfer pricing framework survived, but section numbers, forms and timelines have been reorganised. If your internal templates and TDS working files still quote old sections, they need a clean-up to align with current tax laws.

On withholding tax, the domestic rate on royalty and fees for technical services paid to non-residents is 20% plus surcharge and cess, which is crucial for tax planning services. India's tax treaties with over 90 countries often bring that down to 10% or 15%, and sometimes 5%, which is crucial for corporate tax strategies. But the lower rate is not automatic, and tax risks must be carefully evaluated. Without a valid tax residency certificate, the treaty declaration and a no-PE confirmation, the officer can simply apply the domestic rate, and the Indian payer carries the cost.

The equalisation levy is now history, a significant change in the landscape of corporate tax. The 2% levy on e-commerce supply went in August 2024, and the 6% online advertising levy ended on 1 April 2025, impacting various tax issues. Payments to foreign digital vendors are now tested under ordinary withholding rules and significant economic presence provisions, so old payment classifications deserve a fresh look.

On transfer pricing, the 2026 rules rationalised the safe harbour regime and made the advance pricing agreement process faster. Compliance itself is unchanged in spirit: price related-party dealings at arm's length using one of the six prescribed methods, keep contemporaneous documentation, file the accountant's report in Form 3CEB, maintain a Master File where consolidated group revenue crosses ₹500 crore, and file CbCR where it crosses ₹6,400 crore.

GAAR, the BEPS measures of the Organisation for Economic Co-operation and Development, and the Multilateral Instrument sit above all of this. Large groups also need to track how Pillar Two minimum tax rules being adopted in other countries affect their international tax planning and transfer pricing policies.

How DSRV India Helps With International Taxation

Transaction Structuring
We review the deal before it is signed, not after the notice arrives, ensuring compliance with tax laws. Funding, contract wording and entity choice all move the final tax number.
Withholding Tax Support
We tell you whether to withhold, how much, and what paperwork the remittance needs, so your bank and your auditor both sign off without back and forth.
Transfer Pricing Documentation And Defence
Benchmarking studies, Form 3CEB, Master File and CbCR support, safe harbour and APA advice, plus representation when the TPO makes an adjustment.
Permanent Establishment Reviews
A practical read on whether your activity in India creates a PE, and what to change if the exposure is too high.
Advisory For Multinational Groups
Entry strategy, holding structure and compliance mapping for multinational companies investing into India.
Foreign Tax Credits And Treaty Relief
We build the credit claim with the evidence attached, so relief actually survives scrutiny under the guidance of tax professionals.
Statutory Compliance Management
Advance tax, TDS returns, exemption certificates, audit reports and certifications, tracked against a calendar you can see.
Litigation And Representation
Representation before assessing officers, the Dispute Resolution Panel, CIT(A), tribunals and higher courts is essential for navigating complex tax matters.
Regular Updates
Short, plain-language notes on amendments and rulings that actually affect your business.

Meet Global Tax Experts!

Why Choose DSRV India For International Tax Services?

Three decades of work in international tax, transfer pricing and GST means we have already seen most of what your notice says. Our clients include Indian promoters expanding globally, foreign groups running Indian operations, and families with income in more than one jurisdiction, so advice is built for your facts and not copied from a template.

We also keep it readable. You get a clear answer, 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.

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FAQs About International Taxation Services

What is international taxation?

It is the body of rules that decides how income from cross-border activity is taxed when more than one country has a claim on it. It covers domestic law, tax treaties, transfer pricing and relief for double taxation.

Who needs international tax services?

Any business making or receiving foreign payments, any company with a group entity abroad, foreign companies operating in India, expatriates, and NRIs with Indian income must consider their tax risks.

How do tax treaties reduce my tax?

A tax treaty splits taxing rights between two countries and caps withholding tax on income like dividends, interest, royalty and technical fees. You claim the benefit with a tax residency certificate and the prescribed declarations.

Do I have to withhold tax on every payment to a foreign vendor?

Only where the income is taxable in India, but the safe route is to test each payment before remitting. There is no basic threshold, and the payer bears the interest and penalty for getting it wrong.

Is transfer pricing only for large companies?

No. Any international transaction with an associated enterprise attracts the rules, whatever the size. Documentation and Form 3CEB thresholds are separate from that basic requirement.

Does GST apply to cross-border services?

Yes. Imported services usually attract GST under reverse charge, and exports are zero-rated if conditions are met, affecting cross border transactions. Place of supply and intermediary classification decide the outcome, and they are a common dispute area.

How can I lower my effective tax rate legally?

Through the right structure, treaty benefits, correct income characterisation, timely foreign tax credits and clean documentation. Aggressive arrangements without commercial substance attract GAAR, so we do not recommend them.

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International Taxation Services