International Tax Advisory Services for Global Businesses
From Borders to Balance Sheets: Custom international tax strategies for businesses expanding worldwide.
Global Expansion Without Tax Issues
Expanding your business across borders brings more than just opportunity - it brings certain amount of complexity. Indian businesses wanting to expand globally and foreign companies wanting to enter India, both face a terrain filled with ever-shifting regulations, complex tax rules, reporting standards and legal thresholds.
Whether it is taking care of cross-border transactions, handling Double Taxation Avoidance Agreement (DTAA), understanding Permanent Establishment (PE) exposure, or meeting OECD Pillar Two requirements - international tax needs both local insight and a global view.
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 will offer practical solution that is aligned with your business goals - while staying compliant with DTAA provisions, POEM rules and BEPS guidelines.
With Base Erosion and Profit Shifting (BEPS) now a global focus, we help you handle its impact (profit on taxes) on your cross-border operations. 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.
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.
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.
Partner With Us to Work Towards International Tax Clarity
Handling international tax is no longer a mere back-office task. It plays an important role in shaping how you expand, operate and compete across borders. The risks involved in getting it wrong - double taxation, PE exposure, denied treaty benefits etc., can quietly erode your bottom line.
At MSA, we do not just decode rules. We closely work with you to build practical, forward-looking tax strategies that will support your business goals - whether you are entering India (for business), expanding globally or restructuring your group operations.
Let us help you stay compliant, confident and globally aligned.
Our Key Experts For International Tax
CA Mukunda
Areas of Specialisation:
- Direct Tax Advisory
- Corporate Tax Planning
- Tax Audit Support
- FEMA & RBI Coordination
CA Shiva Prakash H S
Areas of Specialisation:
- International Tax Advisory
- Transfer Pricing
- Strategic Tax Advisory
- M&A Tax Advisory
CA Devendra Nayak
Areas of Specialisation:
- Tax Law Compliance
- Litigation & Representation
- Transfer Pricing Risk Assessment
- NRI Investment Taxation
CA Mani Thoka
Areas of Specialisation:
- Indirect Tax Advisory
- GST Filing & Reporting
- Customs & Excise Advisory
- Expatriate Tax Advisory
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 with businesses abroad or MNCs entering India face at least two or three of these issues. Addressing them at an early stage can mean the difference between a smooth entry and a costly correction later.