International Tax and Transfer Pricing Services in India

Global business has become increasingly interconnected, making international taxation one of the most critical aspects of cross-border business operations. Whether you are a multinational enterprise investing in India, an Indian company expanding overseas, a foreign investor, a start-up with international operations, or a high-net-worth individual with global assets, understanding international tax laws is essential for managing tax risks and ensuring regulatory compliance.

Cross-border transactions are governed not only by domestic tax laws but also by Double Taxation Avoidance Agreements (DTAAs), OECD Transfer Pricing Guidelines, Base Erosion and Profit Shifting (BEPS) initiatives, Multilateral Instrument (MLI), withholding tax provisions, transfer pricing regulations and various reporting requirements. Businesses must carefully structure international transactions to minimise tax exposure while complying with applicable legal and regulatory obligations.

At EzyBiz India Consulting LLP, we provide comprehensive International Tax and Transfer Pricing Services in India to multinational enterprises (MNEs), foreign companies, overseas investors, Indian businesses, start-ups, private equity funds, family offices and high-net-worth individuals. Our professionals advise clients on inbound and outbound investments, cross-border transactions, transfer pricing documentation, DTAA interpretation, Permanent Establishment (PE) issues, international tax litigation and global tax compliance.

Our objective is to provide commercially practical, legally robust and tax-efficient solutions that support international business growth while minimising tax risks and ensuring full compliance with Indian and international tax regulations.

Our International Tax and Transfer Pricing Services

International taxation extends far beyond calculating taxes on overseas transactions. It requires careful planning, detailed legal analysis and a thorough understanding of domestic tax laws, international tax treaties, transfer pricing regulations and evolving global tax standards.

Our professionals work closely with clients to develop tax-efficient business structures, evaluate cross-border transactions, manage international tax risks and represent clients before tax authorities wherever required.

Our key service areas include:

• International Tax Advisory
• Transfer Pricing Advisory
• Cross-Border Transaction Structuring
• Inbound and Outbound Investment Advisory
• DTAA Advisory
• Permanent Establishment (PE) Analysis
• Withholding Tax Advisory
• International Tax Compliance
• Form 3CEB Certification Support
• Transfer Pricing Documentation
• Benchmarking Studies
• APA and Safe Harbour Advisory
• International Tax Litigation
• Mutual Agreement Procedure (MAP)
• Global Tax Risk Management

Inbound Investment Tax Advisory

Foreign companies entering India often face complex tax issues even before commencing operations. The choice of investment structure, business model and funding mechanism can significantly impact the overall tax cost and long-term profitability of the investment.

We assist foreign investors in evaluating the most appropriate entry structure based on commercial objectives, regulatory requirements and tax efficiency.

Our services include:

• Tax planning for wholly owned subsidiaries, joint ventures, branch offices, liaison offices and project offices
• Tax implications of equity and debt funding
• Holding company structure evaluation
• Tax-efficient profit repatriation strategies
• Dividend, interest and royalty taxation
• Exit tax planning
• Capital gains advisory
• Tax implications under applicable DTAAs
• FEMA and RBI tax-related advisory
• Tax due diligence for acquisitions and investments

Outbound Investment Tax Advisory

Indian businesses are increasingly expanding overseas through subsidiaries, acquisitions, joint ventures and international collaborations. Such investments require careful tax planning to optimise the global effective tax rate while complying with Indian tax laws and foreign tax regulations.

Our professionals advise Indian companies on structuring overseas investments and managing cross-border tax obligations.

Our advisory services include:

• Overseas subsidiary structuring
• Cross-border mergers and acquisitions
• Investment holding structures
• Foreign branch taxation
• Repatriation planning
• Foreign dividend taxation
• Foreign tax credit planning
• Overseas business restructuring
• Tax implications under tax treaties
• Coordination with overseas tax advisors

Cross-Border Transaction Structuring

International transactions require careful structuring to achieve commercial objectives while complying with applicable tax laws in multiple jurisdictions.

We assist clients in analysing the tax implications of various cross-border arrangements and recommend structures that are legally sustainable, commercially practical and tax efficient.

Our advisory covers:

• Cross-border supply of goods and services
• International licensing arrangements
• Royalty structures
• Technical service agreements
• Inter-company financing
• Cost sharing arrangements
• Global procurement models
• Shared service centres
• Global capability centres (GCCs)
• Business reorganisations
• Holding company structures
• Cross-border acquisitions and divestments

Double Taxation Avoidance Agreement (DTAA) Advisory

India has entered into Double Taxation Avoidance Agreements with more than 90 countries to eliminate double taxation and facilitate international trade and investment. Correct interpretation of treaty provisions is essential for determining the taxability of cross-border income and claiming treaty benefits.

Our professionals assist clients in analysing applicable tax treaties and ensuring compliance with treaty conditions.

Our DTAA advisory services include:

• Interpretation of treaty provisions
• Determination of tax residency
• Treaty eligibility analysis
• Tax Residency Certificate (TRC) advisory
• Form 10F compliance
• Beneficial ownership analysis
• Foreign tax credit advisory
• Treaty override issues
• Most Favoured Nation (MFN) clause analysis
• Withholding tax optimisation
• Treaty-based tax opinions

Permanent Establishment (PE) Advisory

One of the most significant international tax issues for multinational enterprises is determining whether their activities create a Permanent Establishment (PE) in India or another jurisdiction. The existence of a PE may result in business profits becoming taxable in that country.

Our professionals assist businesses in identifying PE risks, evaluating business models and advising on tax implications arising from cross-border operations.

Our advisory includes:

• Fixed Place PE analysis
• Agency PE analysis
• Service PE evaluation
• Construction PE advisory
• Digital PE considerations
• Attribution of profits to PE
• Documentation support
• PE litigation support
• Advance ruling strategy
• Risk mitigation planning

Why Clients Choose EzyBiz for International Tax Advisory

International tax advisory requires much more than technical knowledge of tax laws. It requires a practical understanding of global business operations, commercial objectives, tax treaties and evolving international tax standards.

At EzyBiz India Consulting LLP, we combine extensive professional experience with a commercially focused approach to help businesses navigate complex cross-border tax issues with confidence.

Our clients value us because we provide:

• Practical and commercially viable tax solutions
• Big 4 experience in international taxation
• Integrated tax, FEMA and regulatory advisory
• Partner-led engagement throughout the assignment
• Research-backed legal opinions
• End-to-end support from planning to litigation
• Responsive and solution-oriented client service

International Tax Due Diligence Services

International acquisitions, mergers, joint ventures and strategic investments involve significant tax risks that may not be apparent from financial statements alone. A comprehensive tax due diligence helps investors identify historical tax exposures, evaluate the tax efficiency of the proposed transaction and negotiate appropriate safeguards before completion.

At EzyBiz India Consulting LLP, we assist domestic and international investors, private equity funds, multinational enterprises and corporate groups in conducting tax due diligence for cross-border transactions, business acquisitions and corporate restructurings.

Our objective is to identify potential tax risks, quantify exposures, assess compliance gaps and recommend practical solutions that facilitate informed commercial decision-making.

Our Tax Due Diligence Services Include

• Buy-side tax due diligence
• Sell-side tax due diligence
• Cross-border acquisition due diligence
• Tax health checks
• Review of historical tax compliances
• International tax risk assessment
• Transfer Pricing due diligence
• DTAA implications
• Withholding tax exposures
• Permanent Establishment (PE) risk review
• GST and indirect tax review (where relevant)
• FEMA and RBI compliance review
• Review of pending tax disputes and litigation
• Identification of contingent tax liabilities
• Post-acquisition tax integration planning

Typical Due Diligence Assignments

Our professionals regularly assist clients in:

• Acquisition of Indian companies by foreign investors
• Acquisition of overseas subsidiaries by Indian companies
• Joint venture transactions
• Cross-border mergers and business reorganisations
• Private equity and venture capital investments
• Strategic investments and business expansions
• Corporate restructuring exercises
• Exit planning and business divestments

Transfer Pricing Advisory Services in India

Transfer Pricing is one of the most significant areas of international taxation for multinational enterprises (MNEs). Countries around the world have introduced Transfer Pricing regulations to ensure that transactions between related parties are conducted at Arm’s Length Price (ALP) and that profits are appropriately allocated across jurisdictions.

India has a comprehensive Transfer Pricing regime under the Income-tax Act, 1961, which applies to international transactions between Associated Enterprises (AEs) as well as specified domestic transactions in certain cases. Non-compliance may result in substantial tax adjustments, interest, penalties and prolonged litigation.

At EzyBiz India Consulting LLP, we provide comprehensive Transfer Pricing advisory and compliance services to multinational groups, Indian subsidiaries of foreign companies, Indian companies with overseas operations, Global Capability Centres (GCCs), start-ups and businesses undertaking cross-border transactions.

Our objective is to help clients establish robust transfer pricing policies, maintain statutory documentation, minimise transfer pricing risks and successfully manage audits and litigation.

Our Transfer Pricing Services

Our professionals provide end-to-end Transfer Pricing services covering planning, compliance, documentation, benchmarking, certification and dispute resolution.

Our services include:

• Transfer Pricing Planning
• Transfer Pricing Documentation
• Benchmarking Studies
• FAR Analysis
• Form 3CEB Certification Support
• Master File Compliance
• Local File Documentation
• Country-by-Country Reporting (CbCR)
• Arm’s Length Price Determination
• Advance Pricing Agreements (APA)
• Safe Harbour Advisory
• Transfer Pricing Audits
• DRP Representation
• Transfer Pricing Litigation
• Mutual Agreement Procedure (MAP)

Associated Enterprise (AE) Advisory

Determining whether two entities qualify as Associated Enterprises (AEs) is the first step in transfer pricing compliance. The Income-tax Act prescribes various criteria based on ownership, management, control and financial relationships.

We assist clients in evaluating whether transactions fall within the transfer pricing provisions and advise on the implications of related-party arrangements.

Our services include:

• Identification of Associated Enterprises
• Review of shareholding and control structures
• Cross-border group relationship analysis
• Identification of international transactions
• Specified Domestic Transaction analysis
• Related-party transaction review
• Documentation of inter-company arrangements

Arm’s Length Price (ALP) Advisory

The Arm’s Length Principle requires that prices charged between related parties should be comparable to those that would have been agreed between independent parties under similar circumstances.

Selecting the most appropriate pricing methodology is critical for demonstrating compliance with Indian Transfer Pricing regulations.

We advise clients on:

• Determination of Arm’s Length Price
• Selection of the Most Appropriate Method
• Comparable company selection
• Comparable uncontrolled transactions
• Economic adjustments
• Risk adjustments
• Profit level indicator (PLI) analysis
• Documentation supporting pricing policies

Functional, Asset and Risk (FAR) Analysis

A robust FAR Analysis forms the foundation of Transfer Pricing documentation. It evaluates the functions performed, assets employed and risks assumed by each entity involved in an international transaction.

We conduct detailed FAR analyses to support transfer pricing policies and benchmarking studies.

Our FAR analysis includes:

• Business model evaluation
• Functional analysis
• Tangible and intangible asset analysis
• Risk allocation
• Value chain analysis
• Characterisation of entities
• Industry analysis
• Economic substance evaluation

Benchmarking Studies

Benchmarking is one of the most important components of Transfer Pricing documentation. It involves identifying comparable independent companies or transactions to determine whether controlled transactions satisfy the Arm’s Length Principle.

Our benchmarking services include:

• Selection of comparable companies
• Database searches
• Quantitative screening
• Qualitative analysis
• Financial ratio analysis
• Profit Level Indicator (PLI) computation
• Multiple-year data analysis
• Working capital adjustment
• Capacity utilisation adjustment
• Economic adjustment reports

Transfer Pricing Documentation

Indian Transfer Pricing regulations require taxpayers to maintain extensive documentation demonstrating that international transactions comply with the Arm’s Length Principle.

Proper documentation significantly reduces litigation risk and strengthens the taxpayer’s position during assessments.

We assist clients in preparing:

• Transfer Pricing Study Reports
• Economic Analysis
• Industry Analysis
• FAR Documentation
• Comparable Company Analysis
• Pricing Policy Documentation
• Inter-company Agreements
• Supporting Financial Analysis
• Audit-ready documentation

Form 3CEB Certification Support

Entities entering into international transactions or specified domestic transactions are required to obtain an accountant’s report in Form 3CEB under the Income-tax Act.

Our professionals assist clients throughout the certification process by:

• Reviewing international transactions
• Identifying reportable transactions
• Reconciliation with financial statements
• Supporting documentation
• Coordination during certification
• Compliance review before filing
• Responding to tax authority queries

Master File, Local File and Country-by-Country Reporting (CbCR)

Large multinational enterprise groups are subject to additional reporting requirements under India’s Transfer Pricing regulations and the OECD BEPS framework.

We assist multinational groups with:

Master File

Preparation and review of global information relating to the multinational enterprise group, including organisational structure, business operations, intangible assets, financing arrangements and overall transfer pricing policies.

Local File

Preparation of entity-specific documentation relating to international transactions undertaken by the Indian entity, supported by benchmarking studies and economic analysis.

Country-by-Country Reporting (CbCR)

Advisory on reporting obligations, filing requirements, exchange of information and compliance with India’s CbCR regulations applicable to qualifying multinational groups.

Advance Pricing Agreements (APA)

Advance Pricing Agreements provide taxpayers with certainty regarding the transfer pricing methodology applicable to specified international transactions over future years. APAs help reduce litigation and improve tax certainty.

We assist clients with:

• APA feasibility analysis
• Selection of covered transactions
• Preparation of APA applications
• Economic analysis
• Interaction with tax authorities
• Negotiation support
• Annual compliance reporting

Safe Harbour Rules

India’s Safe Harbour Rules provide eligible taxpayers with certainty by prescribing circumstances in which transfer prices declared by taxpayers are accepted by the tax authorities without detailed examination.

Our professionals assist in:

• Eligibility evaluation
• Safe Harbour elections
• Documentation
• Compliance requirements
• Renewal and withdrawal considerations
• Comparative analysis between APA and Safe Harbour options

Transfer Pricing Audits and Litigation

Transfer Pricing audits can involve complex economic analysis, extensive documentation requests and detailed examination by tax authorities. Early planning and strong documentation are critical for successfully defending transfer pricing positions.

We represent clients during various stages of transfer pricing proceedings, including:

• Transfer Pricing Officer (TPO) proceedings
• Assessment proceedings
• Dispute Resolution Panel (DRP)
• Commissioner of Income-tax (Appeals)
• Income Tax Appellate Tribunal (ITAT)
• High Court litigation through our network of senior tax counsel
• Mutual Agreement Procedure (MAP)
• Bilateral dispute resolution

Typical Transfer Pricing Assignments

Our professionals regularly advise clients on assignments such as:

International Tax Compliance and Regulatory Advisory

International tax compliance involves much more than filing tax returns. Businesses engaged in cross-border transactions are required to comply with various provisions relating to withholding taxes, reporting obligations, transfer pricing documentation, tax treaty compliance and exchange of information requirements.

Our professionals assist clients in establishing robust compliance processes that minimise tax risks while ensuring timely fulfilment of statutory obligations.

Our international tax compliance services include:

• International tax health checks
• Cross-border tax compliance reviews
• Withholding tax compliance
• International transaction reporting
• Tax residency analysis
• Foreign tax credit compliance
• Tax treaty documentation
• International tax due diligence
• Regulatory reporting support
• Assistance during tax audits and assessments

Withholding Tax and Section 195 Advisory

Payments made by Indian residents to non-residents are often subject to tax deduction at source under the Income-tax Act. Determining whether tax is deductible, the applicable withholding rate and the availability of treaty benefits requires careful analysis of the transaction.

Incorrect withholding may lead to disallowance of expenditure, interest, penalties and prolonged litigation.

We advise clients on:

• Taxability of cross-border payments
• Section 195 withholding obligations
• Royalty and Fees for Technical Services (FTS)
• Interest payments to non-residents
• Dividend taxation
• Capital gains implications
• Reimbursement arrangements
• Grossing-up provisions
• Lower or Nil Withholding Tax Certificates
• Withholding tax opinions
• Tax treaty benefits
• Compliance with remittance requirements

Tax Residency, Foreign Tax Credit and Treaty Benefits

Global businesses and individuals may be liable to tax in more than one jurisdiction. Correct determination of tax residency and treaty eligibility is essential to avoid double taxation and optimise tax efficiency.

We assist clients with:

• Residential status determination
• Dual residency analysis
• Tax Residency Certificate (TRC)
• Form 10F advisory
• Beneficial ownership analysis
• Foreign Tax Credit (FTC)
• Treaty interpretation
• Elimination of double taxation
• Documentation supporting treaty claims

BEPS, MLI, GAAR and POEM Advisory

International tax rules are continuously evolving in response to global initiatives aimed at preventing tax avoidance and profit shifting. Businesses with international operations must evaluate the impact of these developments on their structures and transactions.

Our advisory services include:

Base Erosion and Profit Shifting (BEPS)

We advise clients on the implications of OECD BEPS initiatives, including documentation requirements, substance-based analysis and global tax transparency measures.

Multilateral Instrument (MLI)

We assist clients in understanding how the Multilateral Instrument modifies applicable tax treaties and affects cross-border transactions.

General Anti-Avoidance Rules (GAAR)

We evaluate proposed structures to identify GAAR risks and recommend commercially sustainable alternatives.

Place of Effective Management (POEM)

We advise multinational groups on determining the place of effective management of foreign companies and the resulting tax implications under Indian law.

Expatriate Taxation and Global Mobility Services

Companies frequently deploy employees across international borders for business expansion, project execution and management functions. Such assignments require careful tax planning to ensure compliance in both the home and host countries.

We provide advisory services relating to:

• Taxability of expatriate employees
• Residential status determination
• Salary structuring
• Tax equalisation policies
• Social security considerations
• Foreign tax credit
• Assignment planning
• Cross-border payroll coordination
• Employee stock option (ESOP) taxation
• Departure and arrival tax planning

Industries We Serve

We advise businesses across a broad range of industries involved in international trade, cross-border investments and multinational operations.

Our clients include:

• Manufacturing
• Information Technology and SaaS
• Artificial Intelligence and Technology Start-ups
• E-commerce and Digital Platforms
• Pharmaceuticals and Healthcare
• Automotive and Engineering
• Financial Services
• Banking and FinTech
• Logistics and Supply Chain
• Renewable Energy
• Infrastructure and Construction
• Real Estate
• Global Capability Centres (GCCs)
• Private Equity and Venture Capital Funds
• Family Offices
• Exporters and Importers
• Foreign Subsidiaries in India
• Indian Companies Expanding Overseas

Why Choose EzyBiz India for International Tax and Transfer Pricing?

International taxation demands a combination of technical expertise, commercial understanding and practical experience. Our approach is focused on helping clients achieve tax efficiency while ensuring complete regulatory compliance.

Our key strengths include:

• Experienced team with Big 4 background
• Extensive experience in cross-border tax advisory
• Comprehensive International Tax and Transfer Pricing capabilities
• Practical and commercially focused solutions
• Integrated tax, FEMA, corporate finance and regulatory advisory
• Strong research-backed legal opinions
• End-to-end support from planning to litigation
• Partner-led execution and personalised attention
• Global network of professional associates
• Dedicated support for foreign companies investing in India and Indian businesses expanding overseas
• Integrated Tax & Transaction Advisory – We combine International Tax, Transfer Pricing, Corporate Finance, FEMA, Regulatory Compliance and M&A advisory to deliver practical, end-to-end solutions for cross-border transactions.

Typical International Tax and Transfer Pricing Assignments

Our professionals regularly assist clients in assignments such as:

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Frequently Asked Questions (FAQs)

What is International Tax?

International tax governs the taxation of cross-border transactions, foreign investments, multinational enterprises and income earned across different jurisdictions.

What is Transfer Pricing?

Transfer Pricing refers to the pricing of transactions between Associated Enterprises and requires such transactions to be undertaken at Arm’s Length Price in accordance with applicable tax laws.

Who is required to comply with Transfer Pricing regulations in India?

Entities undertaking international transactions with Associated Enterprises and certain specified domestic transactions may be required to comply with India’s Transfer Pricing regulations.

What is a Double Taxation Avoidance Agreement (DTAA)?

A DTAA is a tax treaty between two countries that seeks to eliminate double taxation and allocate taxing rights between the contracting states.

What is Permanent Establishment (PE)?

A Permanent Establishment is a taxable presence of a foreign enterprise in another country. If a PE exists, business profits attributable to the PE may become taxable in that country.

What is Form 3CEB?

Form 3CEB is an accountant’s report required to be furnished by taxpayers entering into specified international or domestic transactions covered by Transfer Pricing provisions.

What is a Master File?

A Master File contains standardised information relating to the global business operations, transfer pricing policies and organisational structure of a multinational enterprise group.

What is a Local File?

A Local File contains detailed documentation relating to the international transactions undertaken by a specific entity within the multinational group.

What is Country-by-Country Reporting (CbCR)?

CbCR requires eligible multinational enterprise groups to report revenue, profits, taxes paid and other financial information on a jurisdiction-wise basis.

What is an Advance Pricing Agreement (APA)?

An APA is an agreement between the taxpayer and the tax authorities regarding the methodology for determining the Arm’s Length Price of specified international transactions for future years.

What are Safe Harbour Rules?

Safe Harbour Rules prescribe circumstances in which transfer prices declared by eligible taxpayers are accepted by the tax authorities without detailed examination.

Can EzyBiz assist foreign companies investing in India?

Yes. We advise foreign companies on investment structuring, tax treaties, transfer pricing, FEMA compliance, withholding tax, repatriation and ongoing tax compliance.

Can EzyBiz represent clients in international tax disputes?

Yes. We represent clients during assessments, Transfer Pricing audits, DRP proceedings, appeals before the Commissioner of Income-tax (Appeals), the Income Tax Appellate Tribunal and coordinate representation before the High Courts and the Supreme Court through our network of experienced senior tax counsel.

Reviewed by:
CA Anil Agrawal
Chartered Accountant | International Tax & Regulatory Advisor
Big 4 Alumnus | 20+ Years of Experience in Cross-Border Taxation, FEMA & India Entry Advisory
Last Updated: July 2026

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Speak with Our International Tax Experts

Whether you are planning to invest in India, expand your business overseas, restructure cross-border operations or require assistance with Transfer Pricing compliance, our experienced professionals can help you navigate complex international tax issues with confidence.

Contact EzyBiz India Consulting LLP to discuss your requirements and obtain practical, commercially focused solutions tailored to your business objectives.
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Disclaimer

The information provided on this page is for general informational purposes only and does not constitute legal, tax or professional advice. International tax laws, transfer pricing regulations, tax treaties and regulatory requirements vary depending on the facts of each case and are subject to change. Professional advice should be obtained before taking any business or tax-related decisions. EzyBiz India Consulting LLP shall not be responsible for any action taken based solely on the information provided on this page.