Vinay K. Gupta & Co.

We understand the fact that the presence of double or multiple taxation in International taxation acts as one of the determining factors in decisions relating to location of investment, technology etc. which in turn affects the bottom-line of a business enterprise. By rendering our range of Double Avoidance Taxation Agreement we make efforts make sure that the heavy tax burden is not cast as a result of double or multiple taxation. Such agreements are termed as "Double Tax Avoidance Agreements" (DTAA) and "Tax Treaties" and the statutory authority to enter into such agreements is vested in the Central Government. Double Taxation can be avoided by: Two Countries enters into DTAA in order to encourage business and reduce the tax liability on certain kind of Income like :

• Business Income
• Investment Income
  

Royalty Income Benefits:

• Credit of Taxes paid in One country to Home Country
• Maximum Tax Rates
• Or as may be decided in DTAA By offering these services we aim at:
• Evaluating the contract and estimating the benefits of DTAA
• Legal Drafting and submission to Income tax Department
• Litigation Support and Representations
• Consultant and representation
• Corporate and Business Tax Consulting: This service not only covers advice in respect of tax positions, but also transaction advisory services relevant to consummating mergers

We have a host of professionals who has been assisting us in best possible manner to offer services of Transfer Pricing in India. These transfer pricing services help the clients in calculating the alternative business structures from a transfer pricing planning perspective for optimized allocation of revenues between the group entities. These services are affected by the following transaction:

• Any international transactions with any of its group companies
• Any inter-company transactions affecting the operating results
• Render services to/receive services from affiliates free of charge
• Pay or/ receive charges pertaining to intangibles or cost allocations
• Has your company been incurring operating losses over the past few years
• Are you a multinational corporation currently structuring your business plan
• Are you restructuring global operations as a result of changing global conditions compliance and documentation providing assistance in various aspects of transfer pricing documentation preparation and compliance we prepare transfer pricing study which is supported by appropriate sound technical positions reduces the risk of a possible tax contingency

Controversy Resolution as a customer satisfaction oriented firm, we have gained expertise in offering transfer pricing audit management and assistance in handling competent authority negotiations.

Managing Risk Integrated Tax Planning We have gained expertise in providing solutions to international business for comprehensively assessing tax position and driving benefits when our clients deal with us. Combining planning, coordination and execution of tax strategies for devising flexible solutions that effectively address business changes we have been helping our clients while providing them proper consultation to our clients. Back Ground The services that we offer are based on the Increasing participation of multi-national groups in economic activities which has given rise to newer and complex issues emerging from transactions entered into between two or more enterprises belonging to the same multi-national group. Working with a vision of providing detailed statutory framework leading to computation of reasonable, fair and equitable profits and tax in India, we have been working on the set guidelines and acts as incorporated by the Indian government. “In the case of multinational enterprises, the Finance Act, 2001 substituted section 92 with a new section and introduced new sections 92A to 92F in the Income-tax Act, relating to computation of income from an international transaction in relation to the arm's length price, meaning of associated enterprise, meaning of information and documents by persons entering into international transactions and definitions of certain expressions occurring in the said section'. Section 92: As substituted by the Finance Act, 2002 states that any income arising from an international transaction or where the international transaction comprise of only an outgoing, the allowance for such expenses or interest arising from the international transaction shall be determined having regard to the arm's length price. The provisions, however, would not be applicable in a case, where the application of arm's length price results in decrease in the overall tax incidence in India in respect of the parties involved in the international transaction.

Assessing the current transfer pricing policies helps us in overcoming our clients from possible future inquiries from revenue authorities. These services help our clients in reducing the potential risks which can be evaluated for implementation of appropriate corrective actions. Through these services, we have been offering global controversy solutions and resources and confidently addressing this dynamic issue with confidence.