# 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 [All client impact](https://soniassociates.in/case-studies) Private Wealth · Structuring & Tax ### [A multi-year tax plan for a promoter with income across securities, alternative funds, and foreign assets](https://soniassociates.in/case-hni-multi-year-tax-plan) ₹50mn Tax exemptions structured within a single financial year, about US$550,000 Family Enterprises · Structuring & Tax ### [Designing a clean-slate structure for a new agri-tourism group with four distinct business lines](https://soniassociates.in/case-agri-tourism-entity-structuring) 4 Business lines, each taxed differently ## Featured insights [More insights](https://soniassociates.in/insights?topic=tax-structuring) Perspective ### [The Income-tax Act, 2025: a new vocabulary, and the documents still written in the old one](https://soniassociates.in/insight-income-tax-act-2025) September 9, 2026 · 11 min read Article ### [The first foreign subsidiary: decisions that are expensive to reverse](https://soniassociates.in/insight-first-foreign-subsidiary) May 13, 2026 · 10 min read Article · The Audit-Ready Company ### [Selling a majority stake mid-year: consolidation through a loss of control](https://soniassociates.in/insight-loss-of-control-consolidation) August 12, 2026 · 12 min read ## Related ### [Technology & AI](https://soniassociates.in/tech-and-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](https://soniassociates.in/audit-readiness-diagnostic) Fifteen statements, about four minutes, and a scored view of where your audit exposure is concentrated. ### [The Brief](https://soniassociates.in/subscribe) Our fortnightly read on reporting, tax, and structure for CFOs, controllers, and founders. [![Aditya Soni](https://soniassociates.in/assets/img/aditya-soni.jpg)](https://soniassociates.in/aditya-soni) ### [Aditya Soni](https://soniassociates.in/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. [Full profile](https://soniassociates.in/aditya-soni) [LinkedIn](https://www.linkedin.com/in/in-aditya/) Industries [Family Enterprises & Private Wealth · Promoter groups, family offices, and individuals planning for control, succession, and liquidity.](https://soniassociates.in/industry-family-enterprises) [Energy & Infrastructure · Renewable platforms, SPV portfolios, and infrastructure developers reporting to lenders and investors.](https://soniassociates.in/industry-energy-infrastructure) [Consumer & Retail · Multi-location retail, fuel and convenience networks, franchise systems, and consumer brands.](https://soniassociates.in/industry-consumer-retail) Other capabilities [Financial Reporting & Technical Accounting](https://soniassociates.in/service-financial-reporting) [Audit, Assurance & Transaction Support](https://soniassociates.in/service-audit) [Finance Function Transformation](https://soniassociates.in/service-finance-transformation) [Cross-Border & Multi-Jurisdiction Advisory](https://soniassociates.in/service-cross-border) ## 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. [Contact us](https://soniassociates.in/contact?topic=structuring-tax) [LinkedIn](https://www.linkedin.com/in/in-aditya/) --- Soni Aditya & Associates, Chartered Accountants. Office No 502, Unit 507, 5th Floor, 45 Baner Street, Baner, Pune, Maharashtra 411045, India. aditya@soniassociates.in · +91 93400 75288 · https://soniassociates.in/contact This website is published for general information, in keeping with the guidelines of the Institute of Chartered Accountants of India on members’ websites. It does not advertise or solicit work, and nothing on it is professional advice. Publications reflect the law and standards at the date they were written, so please take advice on your own facts before acting. Client engagements described here are anonymised. Site index for agents: https://soniassociates.in/llms.txt Canonical page: https://soniassociates.in/service-corporate-structuring