PROBLEM
Finalizing a contract structure between the lead partner of a consortium and a local power board in India?
METHODOLOGY
We worked with a large Japanese corporation, acting as lead partner of a consortium, by providing inputs on tax implications at the bidding stage and in assisting with negotiation of the final contract terms with the power board.
OUTCOME
We developed a tax prudent advisory at the time of bidding and were involved in finalising the contract split with the power board. This was replicated by the local power board in execution of other similar contracts with international EPC contractors
PROBLEM
Managing the bidding process between a Company dealing with the manufacture and assembly of rolling stock best and a regional Metro Rail Corporation?
METHODOLOGY
We provided context specific inputs to a Canadian company on consortium taxation and consequent structuring of contracts.
OUTCOME
Our advice on consortium taxation enabled the company to effectively leverage its advantages and structure its contracts. We also provided advisory on transfer pricing and documentation on complex transactions involving managerial services and cost contribution arrangements.
PROBLEM
What does an organisation need to consider and implement when representing a tax withholding certificate?
METHODOLOGY
We studied the activities and operating context of a UK OEM supplier of parts and assemblies to Oil and Natural Gas Corporation Limited (ONGC).
OUTCOME
We successfully represented a lower tax withholding certificate before the Indian Income tax authorities.
PROBLEM
What is the legal position on taxability of interest income earned through a specialised scheme of selling equipment to Indian manufacturers?
METHODOLOGY
We examined and researched the transactions of a leading Japanese leasing company and its schemes of selling equipment to Indian manufacturers.
OUTCOME
We assisted in confirming the organisation’s position on taxability of interest income earned through a specialised scheme of selling equipment to Indian manufacturers.
PROBLEM
What are the considerations that determine the establishment of a Permanent Establishment (PE) in India?
METHODOLOGY
We examined the provisions under the Income Tax Act relating to PE and identified the factors that influence the position on the establishment of a PE in India.
OUTCOME
We represented a large Japanese corporation, engaged in trading of specialised machinery, in successfully defending their position with regard to establishment of a PE in India.
