Corporate Structuring & Tax
Group structuring, reorganisations, direct tax advice, and succession planning for promoters and families.
Structures that still make sense after the funding round and the next change in the law.
A group structure is a long-lived decision that usually gets made in a hurry. Entities are set up for whatever deal is in front of the founders, and ten years later the group pays for it: tax leakage whenever cash moves, governance nobody can explain, and a succession that cannot happen without unwinding the past.
We design and reorganise structures with the whole life of the business in mind, across operating companies, holding companies, and family arrangements, and the tax consequences of each. Our direct tax work covers companies and individuals, including multi-year plans for promoters whose income comes from businesses, listed and unlisted securities, alternative investments, and assets abroad.
How we help clients
Group structure design
Operating and holding company structures for new ventures and growing groups, balancing tax efficiency, control, protection from liabilities, and readiness for investors.
- Holding structures
- New ventures
Reorganisations
Mergers, demergers, slump sales, and share swaps, tested against tax neutrality, stamp duty, and the approvals required, before a scheme is drafted.
- Mergers
- Demergers
- Slump sales
Direct tax advice
Positions on characterisation, deductions, and withholding, and the move of contracts and systems to the Income-tax Act, 2025, documented to the standard an assessment will test.
- Income-tax Act, 2025
- TDS
Promoter and private client tax
Multi-year plans across salary, business income, listed and unlisted securities, AIFs, PMS, and foreign assets, with exemptions sequenced deliberately rather than claimed by chance.
- Capital gains
- Private wealth
Succession and family arrangements
Family constitutions, holding arrangements, and succession structures, with governance settled first and the choice of vehicle last.
- Succession
- Family governance
Transaction tax
Tax structuring for an acquisition, a stake sale, or an investment round, including earn-outs, ESOPs, and the exit itself.
- M&A tax
- ESOPs
When clients call us
A new business is being set up
A clean slate is the cheapest moment a structure will ever be designed.
Investors want a holding company
A funding round now depends on a structure the founders have not had time to think through.
Cash moves between group companies without a plan
Loans, guarantees, and dividends between entities carry consequences nobody has mapped.
The next generation is joining
Ownership, control, and roles need separating before disagreement makes that impossible.
A liquidity event is coming
A stake sale, an ESOP exercise, or a property disposal will create a tax bill that planning can still shape.
The law has changed under existing positions
Contracts, declarations, and systems that still cite the Income-tax Act, 1961 need reviewing.
Our approach
Governance before vehicles
We settle who decides, who owns, and who benefits before choosing companies, trusts, or partnerships.
Tax follows design
A structure has to make commercial sense on its own. Tax efficiency comes from designing it well.
Tested against a hostile reading
Every plan is reviewed against the anti-avoidance rules and read the way an assessing officer would read it.
We implement what we recommend
Incorporations, filings, valuations, and documentation are carried out as well as advised on.
Examples of our work
A multi-year tax plan for a promoter with income across securities, alternative funds, and foreign assets
Designing a clean-slate structure for a new agri-tourism group with four distinct business lines
Featured insights
Related
Technology & AI
Withholding and indirect tax analytics across entire vendor and customer populations, catching rate mismatches, missing PANs, and credits that do not agree to returns, alongside scenario models that compare the tax cost of each structuring route before a decision is taken.
Audit-readiness diagnostic
Fifteen statements, about four minutes, and a scored view of where your audit exposure is concentrated.
The Brief
Our fortnightly read on reporting, tax, and structure for CFOs, controllers, and founders.
Aditya Soni
Founding Partner, Pune
Leads the firm’s work in structuring and tax. Advises companies and families on financial reporting, audit readiness, group structure, and tax. Previously in the Assurance practice of Ernst & Young in Pune.
Talk to our Structuring & Tax practice
Tell us what you are working on. A first conversation carries no obligation, and confidentiality applies from the first email.