International Taxation
Businesses with cross-border transactions, foreign subsidiaries, or overseas investors face tax obligations that extend beyond domestic Indian tax law into treaty interpretation, withholding tax, and reporting under FEMA. Hegde Hegde and Associates LLP provides international taxation advisory structured around Indian regulatory requirements and applicable Double Taxation Avoidance Agreements (DTAAs).
Partner reviewedDocumented processBengaluru office
Why International Taxation Matters
Cross-border transactions attract tax treatment under the Income Tax Act 1961, applicable DTAAs, and in many cases, transfer pricing regulations. Incorrect withholding tax computation, treaty misapplication, or inadequate documentation can result in disallowed deductions, penalties, or double taxation.
As global business structures evolve, particularly for technology, export-oriented, and investment-holding entities, international tax positions require ongoing review rather than one-time advice.
Why Businesses Need This Service
- Cross-border payments, such as royalties, technical fees, or dividends, requiring withholding tax and DTAA analysis.
- Foreign investment into an Indian entity, or Indian investment into an overseas entity.
- Overseas subsidiaries or branch operations requiring coordinated tax positions across jurisdictions.
- Expansion into new markets requiring an assessment of permanent establishment risk.
- A need for an international tax consultant to review existing cross-border structures for exposure.
- Repatriation of funds requiring FEMA and tax compliance review.
Our Approach
- 01
Assessment
Reviewing the client’s cross-border transaction structure and existing tax positions.
- 02
Planning
Identifying applicable DTAA provisions, withholding tax rates, and reporting obligations.
- 03
Documentation
Preparing supporting documentation, including tax residency certificates and treaty forms.
- 04
Execution
Advising on transaction structuring and computing applicable withholding tax.
- 05
CA Review
Independent review of positions taken before filing or remittance.
- 06
Compliance Verification
Cross-checking against Income Tax Act, DTAA, and FEMA requirements.
- 07
Reporting
Delivery of advisory notes and supporting computations.
- 08
Continuous Support
Monitoring of treaty updates and regulatory changes affecting the client’s structure.
Scope of Services
- DTAA analysis and treaty benefit eligibility review
- Withholding tax (TDS) computation on cross-border payments
- Permanent establishment risk assessment
- Advisory on inbound and outbound investment structuring
- Support for Form 15CA/15CB certification processes
- Coordination on FEMA compliance for cross-border remittances
- Advisory on taxation of foreign subsidiaries, branches, and liaison offices
Business Benefits
- Reduced risk of double taxation through correct treaty application.
- Improved compliance with withholding tax and reporting obligations.
- Clearer visibility into permanent establishment and structuring risk.
- Documentation that supports tax positions in the event of scrutiny.
- Coordinated tax advice across the entity’s full cross-border structure.
Why Choose Hegde Hegde and Associates LLP
- International tax advisory reviewed by a qualified Chartered Accountant with cross-border tax experience.
- International tax positions coordinated with our transfer pricing and business advisory practices.
- Working knowledge of India’s DTAA network and FEMA regulations.
- Documentation standards suited to scrutiny and audit review.
- Practical advisory grounded in current Indian regulatory context.
Industries We Serve
Our international taxation engagements support technology and IT services companies with cross-border clients, export-oriented manufacturing businesses, startups with overseas investors, and Indian entities with foreign subsidiaries or branch operations.
Technology & IT services
D2C & e-commerce
Manufacturing
Startups & funded ventures
Professional services
NRI individuals
Healthcare
Real estate
Financial institutions
NGOs & trusts
Hospitality
Education
Our Process
Each stage produces a defined deliverable, and nothing is issued to a client before the Chartered Accountant review stage is complete.
- 01
Discovery
Understanding the client’s cross-border transaction profile.
- 02
Assessment
Reviewing existing structures and applicable treaty provisions.
- 03
Documentation Review
Identifying gaps in treaty and withholding tax documentation.
- 04
Execution
Advising on structuring and computing applicable tax.
- 05
CA Review
Independent review before filing or remittance.
- 06
Reporting
Delivery of advisory notes and computations.
- 07
Ongoing Support
Continued monitoring of treaty and regulatory changes.
Frequently Asked Questions
A Double Taxation Avoidance Agreement (DTAA) is a treaty between India and another country that allocates taxing rights over cross-border income, and often provides for reduced withholding tax rates or relief from double taxation, subject to conditions.
Yes. A tax residency certificate from the relevant foreign tax authority is generally required to claim benefits under a DTAA, along with other prescribed forms and declarations.
Form 15CA is a declaration for remittances to non-residents, and Form 15CB is a Chartered Accountant’s certificate confirming the applicable tax treatment. Both are generally required for specified cross-border remittances under the Income Tax Act.
Permanent establishment risk refers to the possibility that a foreign entity’s activities in India (or an Indian entity’s activities abroad) create a taxable presence in that jurisdiction, triggering local tax obligations.
Transfer pricing is a related but distinct area, covering pricing of transactions between associated enterprises. We advise on both together where a client’s cross-border structure involves related-party transactions.
Discuss Your International Taxation Requirements
Whether you are structuring a new cross-border transaction or reviewing an existing structure for compliance and treaty exposure, our team is available to discuss your specific requirement.
Content reviewed by CA Ramkumar Hegde, Partner, Hegde Hegde and Associates LLP.