Cross-Border & Multi-Jurisdiction Advisory
Outbound and inbound investment, FEMA, transfer pricing, and reporting across jurisdictions.
International structures designed for the tax officer who will read them years from now.
Every border a business crosses adds another tax regime, another exchange control regime, and a regulator who will read the structure years later without any of the context in which it was designed.
We advise Indian groups going abroad, and international groups operating in India, on the decisions that are expensive to undo: where to incorporate, how to fund the entity and bring cash home, how to price intercompany flows, and how to stay compliant under FEMA and the overseas investment rules. Where another jurisdiction needs local sign-off, we brief and coordinate independent advisers there and stay accountable for the design as a whole.
How we help clients
Outbound structuring
Where to incorporate, how to fund it, and how cash comes home, for a first foreign subsidiary or a fifth. Overseas investment reporting goes through the authorised dealer bank.
- Overseas investment
- Annual performance report
India entry for foreign groups
Choosing between a subsidiary, branch, liaison office, or LLP; FDI conditions; capitalisation; and the tax, payroll, and compliance set-up that follows.
- FDI
- India entry
FEMA compliance and compounding
Health checks on export and import realisation, advances, and set-offs; regularising older gaps; and compounding applications prepared with complete records.
- FEMA
- EDPMS
- Compounding
Transfer pricing
Intercompany pricing policies, benchmarking, and documentation for services, royalties, financing, and distribution, kept current rather than rebuilt every year.
- Transfer pricing
- Master file
Treaty and residence analysis
Withholding tax positions, treaty eligibility, place of effective management risk, and permanent establishment exposure in both directions.
- Tax treaties
- POEM
- Permanent establishment
Multi-GAAP reporting
IFRS and US GAAP reporting packs for foreign parents, and IFRS or Ind AS reporting for Indian parents with subsidiaries abroad.
- IFRS
- US GAAP
- Group reporting
When clients call us
A customer wants a local contracting entity
Commercial urgency is about to decide a structure that will last ten years.
The bank has flagged unrealised exports
Export entries have aged, and new transactions are starting to attract questions.
A founder is moving abroad
Personal residence, control of the company, and its place of effective management are about to move together.
Intercompany charges have never been priced
Services, recharges, or loans between group entities have no benchmark and no agreement behind them.
A foreign group is entering India
The parent needs an entity, a bank account, payroll, and compliance within weeks, and a structure it will not have to unwind.
Profits are trapped in a subsidiary
Cash sits abroad, and every route home carries tax or regulatory friction.
Our approach
Structures follow the substance
They are built around where people, decisions, and customers actually are. A treaty benefit without substance is a dispute waiting to happen.
Every arrow annotated
Each flow is mapped to its legal instrument, its tax treatment at both ends, and the approval or report it triggers.
The regulatory calendar comes with the design
Reporting deadlines under FEMA and the overseas investment rules are delivered alongside the structure.
One accountable adviser
When foreign counsel is needed, we brief and coordinate them, so the client gets a single joined-up answer.
Examples of our work
Rebuilding an expected credit loss model for a listed IT services company with US$855 million in receivables
A multi-year tax plan for a promoter with income across securities, alternative funds, and foreign assets
Related
Technology & AI
Monthly monitoring that matches export invoices, bank realisations, and EDPMS status and flags entries as they age, and transfer pricing benchmarks refreshed from databases each year instead of rebuilt by hand.
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 cross-border advisory. 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 Cross-Border Advisory practice
Tell us what you are working on. A first conversation carries no obligation, and confidentiality applies from the first email.