WHAT WE DO

Corporate Taxation Services

We assist clients with executing industry-explicit tax collection systems that permit them to acknowledge excellent business esteem. SFA administrations the clients across different verticals as they explore an inexorably perplexing expense scene under both public and global rules.

Our corporate duty administrations can assist with addressing your expense difficulties, presenting inside and out, cutting-edge information on the applicable nearby standards and guidelines and assisting you with staying aware of the always evolving guidelines.

The development of the tax collection system has become extremely intricate. This is significantly because of an expansion in cross-line plans of action. Overseeing such intricacy has become fundamental for endeavors to amplify esteem from each significant business choice.

The Internet based charge consultancy administrations guarantee that you keep up with consistence, and we likewise ensure that we make an incentive for your business, offering you the best assessment guidance and help.

Income Tax

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Transfer Pricing

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Income Tax

Our objective at SFA is to limit your business and individual expense openness through authentic preparation and keeping you mindful of the changing necessities of the tax collection framework in India and abroad. We offer a plenty of completely coordinated corporate personal duty administrations for dynamic organizations in their worldwide tasks as well as nearby activities.

As the simplicity of carrying on with work in India is expanding, financial backers are excited about making interests in the country. Our corporate assessment arranging expert groups give the most duty powerful answers for enormous global organizations, average size organizations, high-total assets people, and business people hoping to develop their organizations.

Effective tax planning is a critical component for businesses, whether they are startups or global multinational corporations, especially with the dynamic changes occurring in the Indian tax system. To align with their goals and objectives, businesses must adopt and adhere to strategic tax planning. Our key corporate tax planning services encompass:

  • Tax Due Diligences & Health Check
  • Place of Effective Management (POEM) & Significant Economic Presence (SEP)
  • General Anti-Avoidance Rules (GAAR) & Base Erosion and Profit Shifting (BEPS)
  • Withholding Tax (WHT) advisory on domestic & international transactions
  • Entity Restructuring for achieving an optimal effective tax rate
  • ICDS: Impact analysis & implementation

With the advent of Faceless Tax Litigation, the Indian Tax Administration is embracing a more transparent and technology-oriented judicial system. However, the ever-evolving tax laws present interpretational challenges and administrative hurdles. Our tax litigation and controversy services address these complexities, offering:

  • Faceless Assessment & Appeals Representation (including CIT-A, Tribunal, High Court & Supreme Court)
  • Advance Rulings (leveraging the new Board for Advance Rulings) & Mutual Agreement Procedure (MAP)
  • NIL / Lower Withholding Tax (WHT) Certificates for both Domestic and International transactions
  • Tax Scrutiny Preparedness (ensuring effective maintenance of tax documentation)

Ensuring adherence to tax compliances involves not only doing things correctly but also doing them at the right time. Our range of corporate tax services within the realm of tax compliances encompasses:

  • Filing of Tax Returns (Corporate, Individual, Trust, Resident / NR, etc)
  • Withholding Tax (WHT) Compliances
  • Group Tax Compliance Management under a unified dashboard
  • Miscellaneous compliances, including Advance Tax, Tax Collected at Source (TCS), and Equalisation Levy

In the last decade, India has made significant strides in the digital realm, propelling businesses to engage and explore global opportunities. As globalization becomes more pronounced, attention must be given not only to Indian tax considerations but also to global tax aspects. Our cross-border taxation services encompass:

  • Advisory on Withholding Tax (WHT) applicability for various international transactions
  • Global Entity Structuring / Restructuring
  • Implications of Permanent Establishment (PE)
  • Assessment of Base Erosion and Profit Shifting (BEPS) and Place of Effective Management (POEM) impact, along with General Anti-Avoidance Rules (GAAR) implications

With the growing global presence of Indian firms and multinational corporations operating in India, there has been a substantial increase in the number of expatriate workforces in recent times. Our services for expatriates encompass:

  • Compensation structuring
  • Social Security advisory & compliances
  • Filing of Tax Returns (in India & outside India)
  • Tax Litigation support in India

In addition to the above, certain individuals such as High Net Worth Individuals (HNIs), Venture Capitalists, CXOs, etc., may require specific tax and succession planning services, including:

  • Family Trust set up & maintenance
  • Office Management services
  • Wealth management advisory

Trust our expertise to address the unique needs of expatriates and individuals with specific tax and succession planning requirements, ensuring comprehensive support for a diverse range of clients.

GST

GST is an exchange charge that has subsumed the majority of the heritage circuitous expenses imposed by the Middle and States. Given the extent of the change, it accompanies its own arrangement of execution difficulties and intricacies. Organizations have returned to their expense structures and have realigned to match the business prerequisite under GST. As the law is similarly new, customary corrections booklets are being given by CBIC.

We have a group of labor and products charge informed authorities. We give GST Administrations in India and guarantee that we agree with GST regulation and in arrangement of offering some incentive driven GST Administrations to our clients.

Doing things not just right, but also at the right time is very essential in adhering to tax compliances. Our gamut of services under GST & tax compliances include:

  • Computation of tax payments and filing of various returns
  • Assist in reconciliation of input tax credits as per the GST system and as appearing in records maintained by the Company
  • Preparation of compliance tracker
  • Assist in queries related to e-Way bills generation
  • Assistance in undertaking GST Annual compliances

With the objective that the taxes are not exported or embedded in the supply chain, refund of GST paid on eligible purchases is extended as refund to exporters and businesses covered under inverted duty structure (i.e., instances where the rate of tax paid on input is higher than the rate of tax payable on outward supplies made). We at SFA, have in-depth knowledge of the intricacies of GST Services in India, undertake cost-benefit analysis and suggest best workable options in client-specific facts including the following:

  • Evaluating the alternatives of refund/rebates and advising on the beneficial method for claim
  • Designing system for generation of necessary documentation for preparing refund claim
  • Assistance in retrieval of supporting documents
  • Preparing refund claim as per statutory requirement
  • Filing refund claim with department and making follow up
  • Making representation in case refund claim rejected

GST is still in nascent stages and evolving both from a policy and implementation perspective there are several uncertainties in interpretation of the provisions. With the possibility of multiple interpretations being taken, several issues resulted in an increased litigation. We at SFA with our experience in handling GST for companies would be glad to assist our clients in:

  • Preparing replies to various notices, drafting appeals, etc.
  • Drafting and filing applications seeking advance rulings
  • Representation services
  • Litigation review exercise to formulate strategy for swift resolution of matters

We shall undertake to review the overall tax positions and GST compliances undertaken by the Company, thereafter, suitably advising for any tax efficiencies. The review is intended to unearth any possible gaps in the tax system adopted. With our experience, we know the possible areas where there can be lapse in the tax system implemented. As a part of review, we shall:

  • Review as-is position of the Company as to whether the same is in consonance with the existing GST provisions
  • Identify risks and opportunities viz. areas of non-compliance and potential tax exposures, areas of savings, etc. and providing suggestions on the same
  • Review of various processes followed by Company from GST perspective

The Foreign Trade Policy has been issued by the Ministry of Commerce to promote and facilitate exports of goods out of India and to also govern imports into the country. Amongst others, the policy provides for

  • Setting-up unit as a STP/EOU
  • Remission of Duties and Taxes on Exported Products (RoDTEP)
  • Rebate of State & Central Taxes and Levies Scheme (RoSCTL)
  • Service Exports from India Scheme (SEIS)
  • Merchandise Exports from India Scheme (MEIS)
  • Import of goods under Advance Authorisation/ EPCG scheme
  • Star House Exporters recognition

We at SFA, have consistently assisted our clients in optimising the claim of different incentives extended under the FTP

Transfer Pricing

MNEs are working in a climate of phenomenal intricacy. The rising volume and assortment of intercompany exchanges amidst a persistently developing exchange valuing arrangements, joined by expanded implementation exercises around the world, have made move estimating a main gamble the executives issue for worldwide organizations.

SFA, with its rich experience and exhibited capacities, have confidence in giving comprehensive exchange estimating answers for clients customized to meet business goals and simultaneously be strong, versatile, and practical from a BEPS and neighborhood move evaluating guidelines viewpoint.

SFA gives exhaustive exchange valuing arrangements enveloping – move estimating administrations for new related party exchanges and move evaluating documentation (as legally endorsed by nearby wards). We give start to finish prosecution support across legal gatherings on all Move Valuing matters.

We likewise help MNEs in Planning and assessing elective question goal courses – Advance Valuing Arrangements, Move Estimating Review, Common Understanding Method, Move Evaluating Documentation, and Safe Harbor Rules. Further, with the appearance of BEPS, MNEs need to guarantee consistence with BEPS Activities Plans (counting recording every one of the applicable structures connecting with three-layered documentation). SFA helps with guaranteeing that the data revealed in the Country-by-Nation Report, Expert Document, and Neighborhood Record enough factors a 360-degree view and supports the Exchange Valuing and other duty places of the MNEs and shows the consistence of the MNEs with OECD and nearby exchange evaluating guidelines.

  • Transfer Pricing Compliances
  • Transfer Pricing Documentation
  • Accountant’s Report – Form No. 3CEB
  • Master File
  • Country-by-Country Report
  • Global Transfer Pricing Compliance – Regional/Country comparable studies & filings adhering to OECD guidelines and local regulations. (SBC has access to all major Indian and Global databases/software – Prowess, CapitalineTP, AceTP, Amadeus, Compustat, Kt-Mine, RoyaltyRange, RoyaltyStat, Orbis, Osiris, IBISWorld, Factiva, One Source, Loan Connector, etc.)
  • Transfer Pricing Comfort Letters/Memos for Statutory Auditors
  • FIN 48 Assistance – Quantification & Opinion on Transfer Pricing exposure and uncertain tax positions
  • Transfer Pricing analysis and Board meeting presentations for Listed Companies from SEBI Regulations and Companies Act perspective.
  • Transfer Pricing Policy & Price Setting
  • Drafting/Review of Inter-Company Agreements
  • Alternative Business and Remuneration Models that are sustainable
  • Comparable Studies and Benchmarking analyses
  • Operational Transfer Pricing
  • Group Profit & Effective Tax Planning
  • Tax efficient structuring of international transactions & transaction flows
  • Supplementary analyses to strengthen the documentation from litigation perspective
  • Voluntary Transfer Pricing Adjustments
  • Secondary Adjustments
  • Transfer Pricing Health Check-Up to avoid/mitigate risks
  • Transfer Pricing Due Diligence
  • Drawing Segmental P&L for Transfer Pricing Purposes
  • Economic adjustments computation – Risk, Working Capital, Forex, Capacity Utilisation, Depreciation, Cash PLI adjustments
  • Intangibles – Structuring, Royalty & Licencing rates, Withholding implications, Agreements
  • Financial Transactions – Interest rates, Withholding implications, Agreements
  • Intra-Group Services, Management Charges, Cost Contribution Arrangements – Charging/mark-up rates, Agreements, Cost pooling & allocation
  • Business Restructurings – Transfer Pricing implications, Agreements & Contracts review
  • General Anti Avoidance Rules (GAAR) implications
  • Permanent Establishment (PE) Exposure for existing/proposed transactions
  • First level authorities – Transfer Pricing Officers (TPO)/ Assessing Officers (AO)
  • Dispute Resolution Panel (DRP)
  • Appellate authorities – Commissioner of Income Tax (Appeals) [CIT(A)], Income Tax Appellate Tribunals (ITAT), High Court, Supreme Court
  • Penalty, Rectification, Re-assessment, Revision, Remand, Order giving effect, Stay of demand proceedings
  • Cost Benefit Analysis for decision making
  • Filing of Applications in prescribed Forms
  • Representations & Submissions
  • Application Renewals
  • APAs – both unilateral & bilateral
  • BEPS Contract Analysis
  • Value Chain Analysis and Management
  • OECD Pillar 1 & 2 – Readiness, Implementation & Impact
  • Supply Chain Restructuring
  • Three Tier Documentation support in line with Action 13
  • IP Structuring /DEMPE analysis in view of Action 8
  • Financial Transactions planning factoring in Action 4 and 9 and OECD guidelines on Financial Transactions
  • High risk transactions structuring in coherence with Action 10
  • Profit Split Method – applicability, implementation, splitting factors, projections, segmentation, planning/price setting as per BEPS
  • Assets (tangibles & intangibles) transfer between related parties
  • Capital/financial transactions (equity, debt & hybrid instruments, guarantees) – issue, sale, buybacks between related parties
  • Mergers & Acquisitions transactions – selling, buying, combining, restructuring involving related parties
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