One of the most important parameters for doing business around the world is the ever-changing and complex nature of corporate taxation and regulatory compliances. Therefore, it is imperative for business leaders to understand the developments in tax and regulatory requirements, their impact on doing business in that jurisdiction and to identify means and methods to use them strategically and tactfully to your advantage. Therefore, formulating, and harmonizing tax strategy to the existing business strategy is a critical aspect to maximize the profit objective.

At BSC, we understand that effective tax planning for enterprises requires both technical resources and in-depth knowledge of each client’s unique financial situation. Our network of experienced tax professionals can assist in resolving various tax challenges to business and keeping abreast with tax regulations. Our professionals bring innovative and insightful approaches to a variety of intricate tax issues. Backed by the knowledge and resources of our extensive national network, BSC delivers comprehensive tax planning and advisory services to meet individual need of specific business unit.

The services provided under this can be broadly categorized as under-

• Advisory on the residential states of the Individual, being a global citizen and / or business entities bring corporates, partnerships, trusts
• Advisory on the risks of risks of permanent establishment in India for the overseas entities having business relationships with India
• Advising on the withholding tax implications on cross border transactions of sale of services, goods, royalties etc.,
• Advisory on structuring the global businesses having regard to the domestic taxes as well as tax treaties amongst countries
• Advisory on cross border investments, exits, mergers, demergers as well as joint ventures and collaborations
• Advisory on cross border repatriation of funds in a tax effective manner.
• Advisory on and assisting in claiming foreign tax credits in India

Our global tax compliance process ensures that your direct and indirect taxes are correctly and timely administered. Our tax advisors will also assist you in saving valuable time spent on mandatory activities that ensure your company’s compliance with local tax regulations, such as preparing tax returns/filing, responding to local tax authorities’ inquiries, and representing your company during inspections.

Our experienced tax professionals are ready to assist you in the following areas to ensure that you are in compliance with your statutory return, disclosure, and documentary obligations:

• Tax registration, tax returns and bookkeeping services.
• Opportune Record keeping and filing of tax returns.
• Ongoing tax compliance, accounting, and reporting services.
• Representing before the authorities during the scrutiny and statutory inspections.

The integration of national economies and markets has increased in recent years, putting a strain on the international tax rules, which were designed more than a century ago. Weaknesses in the current rules create opportunities for base erosion and profit shifting (BEPS), requiring bold moves by policy makers to restore confidence in the system and ensure that profits are taxed where economic activities take place and value is created.

The OECD and G20 countries adopted a 15-point Action Plan to address BEPS in September 2013. The Action Plan identified 15 actions along three key pillars: introducing coherence in the domestic rules that affect crossborder activities, reinforcing substance requirements in the existing international standards, and improving transparency as well as certainty. The BEPS package of measures represents the first substantial renovation of the international tax rules in a century.

As a first step, OECD and G20 finalized the multilateral instrument (MLI) in 2016 to facilitate the implementation of the treaty related BEPS measures. The MLI effective from 1 July 2018 has paved the way for swift implementation of the treaty related measures. This paved a way for an OECD / G20 Inclusive Framework (IF) comprising of 135 countries which is monitoring the implementation of minimum BEPS standards and addressing BEPS issues.

The IF countries have recently developed consensus on the framework for addressing tax challenges arising from the digitization of the economy under a two-pillar approach with Pillar One focused on nexus and profit allocation and Pillar Two focused on a global minimum tax intended to address remaining BEPS issues.

At BSC, our experienced tax professionals are ready to assist multinational enterprises (MNEs)in this ever-changing field of the international taxation

1. Advisory in interpretating the tax treaties along with the MLI and its implications thereof on MNEs
2. Evaluating the impact of the BEPS initiatives on the businesses and the overall tax impact on the MNEs
3. Advisory on the need for changes to the business operations and structures and tax planning opportunities
4. Advisory in relation to filing of tax returns, applying for foreign tax credits, making disclosures amid the new framework

BSC’s Global Transfer Pricing Compliance Services provides high-quality and cost-effective assistance for global master file and local file transfer pricing documentation, benchmarking, and Country-by-Country reporting obligations.

Global Compliance Services are performed by experienced transfer pricing professionals, ensuring high quality on a global scale, and the services under this head are broadly categorized as under.

• Preparation of OECD-compliant master files or updating existing master files to ensure suitability, as well as assistance with Country-by-Country reporting compliance.
• Customization of OECD-compliant master files to meet local requirements while taking into account local nuances.
• Preparation of local file transfer pricing reports in order to ensure full compliance with local regulations and reduce risks.
• Translation of documentation where required by the local legislation or were expected by the local tax authority.

Proliferation of number of intercompany transactions has made transfer pricing a leading risk management issue for global businesses. When businesses change their structures and adjust their transfer prices, the affected countries suddenly lose a share of tax revenue. To mitigate such losses, these countries introduce transfer price adjustments. So, if a company restructures its worldwide operations without considering these variables, they could face significant penalties and double taxation. In view of the same International business is faced with increasing transfer pricing documentation requirements, together with changing laws and regulations.

At BSC, our transfer pricing team assists Indian and Multi-National Corporations to develop implement, manage and defend economically justifiable transfer pricing policies and processes. Our professionals work with the client to develop the effective, prudent, and integrated strategies that address the tax risks of today’s businesses and help our client’s business achieve its potential. We also help clients to document their transfer pricing policies in a comprehensive, and consistent manner.

Comprehensive Tax Services

In addition to transfer pricing, we provide expertise in several other key areas:

• Offering detailed guidance and strategies to optimize personal income tax positions and ensure compliance with all regulations.
• Assisting businesses in navigating the complexities of consumption taxes, including VAT and GST, to ensure proper compliance and optimization.
• Providing support in managing customs duty obligations to facilitate smooth international trade and compliance with customs regulations.

The services provided under this can be broadly categorized as under-

• Assist businesses develop and implement commercially feasible and fiscally efficient transfer pricing policies
• Assisting companies in assessing the potential impact of transfer pricing policies on their overall tax position
• Assisting companies in testing and reporting transfer prices and developing processes and tools to monitor transfer results.
• Evaluating and implementing a suitable invoicing mechanism based on sound transfer pricing logic
• Helping you structure intercompany agreement (documents)