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A practice anchor at D Somani & Associates

International Taxation.


At a glance

The five things you need to know.

What it is

Cross-border tax structuring, DTAA analysis, withholding-tax certifications and transfer pricing under the Income Tax Act, 2025.

Who it's for

Indian companies with foreign operations, NRIs and foreign nationals with India income, multinationals with related-party transactions.

How we run it

Tax memos that document position and reasoning. TP studies built on real comparables, not boilerplate.

You walk away with

Tax positions documented in writing, certifications, TP studies and documentation, and a clear cross-border tax memo.

Typical timeline

Certifications: same-day to 3 days. TP study: 4-6 weeks. Cross-border advisory: case-by-case.

What we do.

International tax is the place where small errors become expensive. We run a quiet, document-first practice - every position is written down, every certificate carries its reasoning, every TP file traces back to real comparables.

DTAA analysis and application.

Decision-tree-led analysis for foreign remittances - residence article, beneficial ownership, MFN clause where applicable, TRC requirements. Written memos so your CFO can take the position to internal audit or to the tax authority without a second meeting.

Withholding tax certifications.

Certifications for outbound remittances under the Income Tax Act, 2025, with the underlying analysis documented. We issue these on a same-day to 3-day basis.

Transfer pricing.

TP study and documentation built around real comparables and your actual transaction profile - not a template that's been cloned across thirty clients. We cover related-party transaction benchmarking, master file, local file, and CbCR where applicable.

How we are different.

  • One firm, one consistent story. International tax sits inside the same firm as FEMA and internal audit, so your position holds together across every certificate and every return.
  • Written tax memos by default. Every non-routine position is documented before it's taken. Survivable to scrutiny, defensible at appeal.
  • Updated for the Income Tax Act, 2025. All advisory work reflects the new code, not legacy interpretations.

Taxation of non-residents.

For NRIs and foreign nationals with India income - what's taxable, repatriation routes (NRO / NRE / FCNR), surcharge and cess interplay, and the planning mistakes we see most often. We work the cross-border position alongside our FEMA team so the tax and regulatory answers match.

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