KCM helps in structuring cross border transactions of tangibles, intangibles and services and inbound and outbound investments for achieving high tax efficiency and minimize the tax risks on an overall basis.
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Transaction Advisory

TP Planning Studies help in overall basis. adhering to the arm’s length standard. It also has significant evidential value to establish, before the tax authorities, the considerations that were available at the time of pricing decisions. The TP Planning Studies are very useful in case of nontrade transactions, which pose maximum risk of TP adjustment by tax authorities. KCM has resources (including domestic and international databases) to carry out Planning Studies for variety of transactions listed here. KCM has not only carried out these benchmarking exercises but has successfully defended before the tax authorities.

Expatriate Arrangement Structuring

Expatriate arrangements have a chain of tax issues, ranging from remuneration taxation in the home country and host country, availability of tax credits, permanent establishment, service tax, social security issues, exchange control issues, and so on. Therefore, it requires an in-depth analysis of expatriate arrangement before it is implemented on any model. KCM advises its client with regard to the appropriate expatriate arrangement and assists in preparing necessary agreements to give effect thereto.

KCM has to its credit several path breaking rulings dealing with complex international tax issues, including issues related to interpretation of double tax avoidance agreements (DTAA), fees for technical services, allocation of HO expenses, non discrimination, and so forth.

TP Planning Studies

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