Where small errors become expensive. Every position written down.

A quiet, document-first practice. Every non-routine position is written down before it is taken, every certificate carries its reasoning, every transfer-pricing file traces back to real comparables.

• A remittance abroad that needs a certificate this week.
• A related-party transaction with a foreign group company.
• An NRI or foreign national with India income and three different answers on how it is taxed.
• A notice that questions a position nobody documented.

A position that was never written down cannot be defended. Withholding applied at the wrong rate becomes the payer’s liability; a transfer-pricing file cloned from a template fails at the first scrutiny.

1. DTAADecision-tree analysis for foreign remittances: residence article, beneficial ownership, MFN clause where applicable, TRC requirements. A written memo your CFO can hand to the assurance team or the tax authority.
2. CertificationsWithholding-tax certificates for outbound remittances under the Income-tax Act, 2025, with the analysis documented, same day to three days.
3. Transfer pricingStudy and documentation on real comparables and your actual transaction profile: benchmarking, master file, local file, CbCR where applicable.
4. Non-residentsWhat is taxable, repatriation routes (NRO, NRE, FCNR), surcharge and cess interplay, worked alongside the FEMA team so the tax and regulatory answers match.

• Tax memo for every non-routine position.
• Certifications with reasoning attached.
• Transfer-pricing study and documentation.
• One cross-border file where tax and FEMA agree.