INTERNATIONAL TAXATION

Multinational businesses are buffeted daily by tax, legislative and regulatory developments around the world. Mastering their impact on business operations and cross-country transactions is vital to a company’s survival. NMCO network of highly experienced international tax services professionals is here to help, in every way, and everywhere you do business.

For all of its complexity, the area of international tax boils down to a single imperative: Reduce your global effective tax rate. We offer innovative international tax-savings ideas that align with your overall business objectives and the way your company operates.

India is the world’s largest democracy and one of the fastest growing economies. As multinationals across the world shift their focus and approach to India, it is important that the country’s tax and regulatory policies are well understood for optimizing growth and success opportunities. Industry focus is fundamental to our approach and encompasses sectors of financial services, information, communication and entertainment, consumer markets, industrial markets, and infrastructure and government. Our service offerings

a. Planning & structuring the inbound and outbound investments: Complete set of advisory on entire planning of the foreign investments. Listing down the most advantageous mode for entry in India. Similarly analyzing the most suitable for outbound investments. This also includes looking through the global tax scenario.
b. Expatriate tax advisory: The entire checklist for the expatriate taxation in India including the check-in and check-out briefings on India tax. Also, includes opinions on availability of various tax exemptions as per Income Tax Act, tax credits as per DTAA.
c. Certification for abroad remittances u/s 195: The e-filing of Form 15CA & Form 15CB, determination of withholding tax liability on international taxation and issuance of certificate for enabling remittance would be included in the above.
d. Tax implications on constitution of Permanent Establishment. Interpretation of business processes for cross border workings, to analyse the formation of a Permanent establishment. Forming a PE would lead to assigning of relevant part of global revenues as per the activities performed by Indian Counterparts.
e. Tax Opinion on transactions with non-residents, DTAA. Various considerations and important implications on transacting with foreign exchange are analysed and opined. The beneficial provisions if any available while dealing with treaty existing countries.

Transfer pricing is a term used to describe inter-company pricing arrangements relating to transactions between related business entities. These can include transfers of intellectual property, tangible goods, services, and loans or other financing transactions. Transfer Pricing in India was introduced in 2001 for curbing tax avoidance by laying down norms for computation of income arising from international transactions having regard to the ” arm’s length price”.

The use of transfer pricing tax strategies has recently attracted a high level of international attention, due in part to the rapid rise of multinational trade, the opening of several significant developing economies and transfer pricings increased impact on corporate income taxation. Further, this approach also ensures a creative and dynamic tax planning process for our clients.
In response to these factors, tax authorities around the world have become more aggressive in the transfer pricing arena, introducing stricter penalties, new documentation requirements, increased information exchange, improved audit staff training and increased audit and inspection activity and specialization.

In recent years, transfer pricing has emerged as a critical success factor in corporate strategic planning and executive decision-making. Our transfer pricing professionals can assist you in all phases of transfer pricing planning and in avoiding costly defense actions.

Tax authorities in India have stepped up their scrutiny on cross-border related party transactions and the amount of adjustments done in the recent past is testimony to the fact that transfer pricing is a primary focus area.

We develop benchmark and customized solutions to reduce the overall tax burden of our clients wherever they operate.

Our integrated global network of international tax professionals helps you manage your business tax burden by uncovering opportunities, managing global tax risks and meeting cross-border reporting obligations. Using multidisciplinary teams, we work with you to manage global operational changes and transactions, capitalization and repatriation issues, transfer pricing and tax efficient supply chain management – from forward planning, through reporting, to maintaining effective relationships with the tax authorities. Our talented people draw on their global insights and perspectives to help you build proactive and integrated global tax strategies that address the tax risks of today’s businesses and help achieve sustainable growth. It’s how we makes a difference.

We provide assistance in the following areas :

1. Arriving at a realistic Valuation
2. Gaining an overall understanding of the sector and providing an unique insight into the potential target
3. Helping to effectively face competition, technology, customers, legislation, powerful buyers, the emergence of new geographic markets and other issues
4. Validation of available data
5. Tackling Competitive Uncertainty
6. Helping clients spot opportunities

The relevant areas of concern may include the financial, legal, labour issues, tax, IT, environment and market/commercial situation of the company. Other areas include intellectual property, real and personal property, insurance and liability coverage, debt instrument review, employee benefits and labour matters, immigration, and international transactions. Our dedicated staff can provide the necessary expertise and share with clients our in-depth industry and market know-how to identify and address the key issues quickly and viably. Thus, the client is assured of cost-time efficiency.

Mergers & Acquisitions activity has seen a marked increase over the past several years. Need for business and financial restructuring, consolidation of businesses and increased competition amongst domestic and multinational companies have combined to spur Mergers & Acquisitions activity in India.

The myriad legal and regulatory provisions call for a high degree of experience, skills and multi-faceted knowledge. We provide expert services in the following areas:

a. Planning & Advising Mergers & Amalgamations
b. Corporate Restructuring
c. Financial re-engineering & Business Valuation
d. Internal Restructuring
e. Strategic Acquisitions & Takeovers
f. Deal Negotiation & Structuring
g. Equity Divestments
h. Demerger/ Strategic Sale

To impart specialised focus to Mergers & Acquisitions, NMCO has a dedicated team of professionals in the Mergers & Acquisitions group who have a blend of skills and experience to provide valuable insights and innovative solutions for clients to maximize value for their business and investments, whilst mitigating the risk of doing business in a changing environment.

We provide advice and assistance on :
1. Ensuring Tax Efficiency in group structure
2. Consolidation of related Businesses
3. Assistance in disposals, management buy-outs, buy-ins, fundraisings, Initial Public Offerings, takeovers
4. Optimum Capital Structuring
5. Corporate Restructuring
6. Pre-deal evaluation
7. Transaction evaluation
8. Carrying out pre-acquisition due diligence

We work with you throughout the transaction lifecycle, helping you to achieve your strategic objectives across acquisitions, disposals, management buy-outs, buy-ins, fundraisings, Initial Public Offerings, takeovers, mergers and strategic reviews.

Our M&A professionals around the world deliver that kind of unique support to meet the needs of our clients every day. Our capability allows us to guide companies through cross-border deals with an understanding of local culture and business environments. Our multi-functional teams offer comprehensive and strategically focused tax, accounting, consulting and advisory services covering various industry sectors.

From beginning to end, we align our services to address your transactional and integration needs, all with the goal of building value for our clients.