International Tax Advisory Services for Global Businesses

From Borders to Balance Sheets: Custom international tax strategies for businesses expanding worldwide.

Expanding your business across borders brings more than just opportunity - it brings certain amount of complexity. Indian businesses looking outward and foreign companies wanting to enter India, both face a terrain filled with ever-shifting regulations, tax treaties, reporting standards and legal thresholds.

Whether it is managing cross-border transactions, decoding a Double Taxation Avoidance Agreement (DTAA), understanding Permanent Establishment (PE) exposure or complying with OECD Pillar Two requirements - international tax matters demand local insight and global thinking.

From withholding tax complications to Base Erosion and Profit Shifting (BEPS) compliance, from transfer pricing disclosures to claiming foreign tax credits - businesses need guidance that involves technical depth with practical advice. That is where we come in.

At MSA, we help you plan your inbound and outbound business structures with tax efficiency in mind. Whether it is cross-border M&A, fund structuring or transfer pricing documentation, our team offers practical solutions that align with your business goals while staying compliant with DTAA provisions, POEM rules and BEPS guidelines.

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Why International Tax Strategy Matters Today

Global tax rules are changing faster than ever - and companies that adapt early will gain more than just compliance.

Tax is Not Just Compliance Anymore

International tax is no longer just about filing on time or reading treaty clauses. It is now more about managing your global footprint smartly. Whether you are an Indian company exploring new markets or an MNC setting up in India, your tax decisions will now affect everything from profitability to deal timelines.

New Global Rules Are Reshaping Old Structures

With OECD Pillar Two, BEPS, GAAR and MLI coming into play, regulators are focusing on how value is created and where profits are being reported. Tax authorities are also equally paying closer attention to Permanent Establishment (PE) exposure, transfer pricing policies and use of tax treaty networks.

Avoid Roadblocks in Cross-Border Growth

If your legal entity structure, inter-company charges or royalty agreements are not aligned with today's global standards, it can then lead to costly audits or blocked transactions. A strong international tax strategy will help you avoid these roadblocks, manage risks and stay competitive wherever you operate.

Everyday Tax Challenges That Slow Global Expansion

Cross-border tax issues are not always complex on paper - but in practice, they can quietly chip away at profitability or delay expansion plans. Here are some common hurdles businesses face:

PE exposure from overseas employees or service delivery
Inefficient group structures causing excessive tax outflow
Trouble in repatriating profits due to dividend taxes or regulatory bottlenecks
Transfer Pricing mismatches leading to disputes and audit risks
Incomplete DTAA documentation causing higher withholding tax
OECD Pillar Two rules increasing tax liabilities across low-tax jurisdictions

These are not rare cases. Most Indian companies going abroad or MNCs entering India face at least two or three of these issues. Addressing them early can mean the difference between a smooth entry and a costly correction later.

International Tax Services: A 360° Approach to Global Tax Management

Get to know our tailored solutions for cross-border taxation, treaty benefits, transfer pricing and regulatory compliance - built for global businesses operation.

DTAA & Treaty Advisory

We will help you interpret tax treaties and secure relief under the right article. We will also support you with Tax Residency Certificate (TRC) applications, Form 10F filing and documentation needed to claim DTAA benefits under Indian Income Tax Rules.

Withholding Tax Compliance & Support

We will guide you to apply correct withholding tax rates on payments like royalties, interest or service fees. We also assist you with Form 15CA/CB preparation, certificate issuance under Section 195 and filing procedures to avoid non-compliance penalties.

Transfer Pricing Support with Filing

From benchmarking and inter-company contracts to preparing Form 3CEB and Country-by-Country Reporting (CbCR), we help you stay compliant with Indian transfer pricing laws. We will also review master file obligations and assess BEPS-related exposures.

Permanent Establishment (PE) Risk Assessment

Our team of CAs will assess whether your overseas or Indian operations may trigger a PE and lead to unexpected tax liabilities. We then suggest operational and structural adjustments to manage PE exposure under domestic law and tax treaties.

Cross-Border M&A and Fund Structuring

Our experts will assist you with tax-efficient structuring of inbound and outbound M&A deals, joint ventures and fund setups. We help you by evaluating holding structures, deal timing, exit tax costs and GAAR impact - all while aligning with your business intent.

Pillar Two Readiness and Modelling

We help you evaluate the impact of OECD's Pillar Two global minimum tax on your group structure. This includes modelling effective tax rates, identifying covered taxes and preparing data for GloBE (Global Anti-Base Erosion) compliance and reporting.

International Tax Compliance and Representation

Our experts will help you manage regulatory filings, disclosure requirements and represent you before tax authorities for international matters. This includes DRP, ITAT, APA forums and responding to queries on international transactions, PE and treaty interpretation.

FEMA & RBI Reporting for Cross-Border Transactions

We support Indian entities in complying with FEMA regulations and RBI reporting requirements, including FCGPR, FLA returns and share transfers. Our advisory will make sure that transactions like inbound investments or overseas remittances stay within regulatory guardrails.

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Your Global Ambitions Deserve Smarter Tax Thinking

When your business crosses borders, tax is not just a cost - it becomes a strategic lever. From choosing the right structure to managing treaty benefits and modelling future tax impact, every choice affects profitability. With increasing scrutiny, regulatory overlap and global reporting rules, it is no longer enough to just stay compliant. You need to stay ahead.

Let us help you turn international tax complexity into a driver of clarity, growth and control.

Get Your Questions Answered

International tax is no longer a back-office task. It shapes how you expand, operate and compete across borders. The risks of getting it wrong - double taxation, PE exposure, denied treaty benefits - can quietly erode your bottom line.

At MSA, we do not just decode rules. We work with you to build practical, forward-looking tax strategies that support your business goals - whether you are entering India, scaling globally or restructuring group operations.

Let us help you stay compliant, confident and globally aligned.