I.    Cross Border Taxation

II.    Transfer Pricing

III.    Taxation of Expatriate

IV.    Filing of Form 15CA & CB

V.    NRI Taxation Services

With globalization comes a complex maze of international tax laws and regulations that companies are required to comply with to ease the global operations.

RAAC is a proficient CA firm in international tax advisory services and international tax consultancy services. We, at RAAC, help the organizations with compliance with the prerequisites of international taxation principles, analyze the costs and benefits associated with geographical expansion for the clients, and advise them accordingly. Whether you are a foreign organization, intending to expand in India, or vice versa, our team of international tax advisors, can aid you in strategizing for these initiatives. It involves the application of tax laws and regulations in different countries and can involve issues such as double taxation, transfer pricing, and tax havens.

Cross Border Taxation

We specialize in providing solutions for businesses involved in international operations, ensuring compliance with tax regulations across jurisdictions. Our services include:

•        Taxation of cross-border transactions.

•        Structuring tax-efficient international business operations.

•        Resolving double taxation issues under DTAA (Double Taxation Avoidance Agreements).

Cross-Border Tax Advisory

Our advisory services help businesses optimize their global tax strategies, including:

•        Strategic tax planning for cross-border mergers and acquisitions.

•        Advising on permanent establishment (PE) risks and profit attribution.

•        Guidance on indirect taxes like VAT, GST, and customs duties in cross-border trade.

Cross-Border Tax Accounting

•        We provide comprehensive accounting support for international taxation, including:

•        Accurate financial reporting for global operations.

•        Assistance with transfer pricing documentation and compliance.

•        Consolidation of financial statements in line with global tax norms.

Specialized Tax Services

Our expertise extends to niche areas, including:

•        Taxation of cross-border mergers and acquisitions.

•        Tax compliance for expatriates and inbound employees.

•        Advisory on treaty benefits and withholding tax optimization.

Transfer Pricing Services

Businesses, which operate globally, face higher risks due to exposure to multiple jurisdictions and multiple laws.

There are many intercompany transactions, which make transfer pricing planning, related tax structuring, documentation, risk assessment, compliances, and litigation services a critical requirement for global businesses. The expansion of the global markets has made transfer pricing a general phenomenon rather than a one-of-a-kind. RAAC is one of the leading transfer pricing services providers. Our experience in transfer pricing matters, combined with our professional approach, helps the clientele handle such transactions smoothly without any glitches.

Transfer Pricing Advisory Services

RAAC is engaged in managing clients' domestic and international transfer pricing transactions through its team of capable, experienced, and skilled transfer pricing consultants. Our transfer pricing services include transfer pricing studies, documentation, auditing, policy determination, determination of arm's length price (ALP) in accordance with Safe Harbor Rules (SHR), country-by-country (CbC) reporting, Advance Pricing Agreement (APA), transfer pricing certification (Form 3CEB), and many more.

Transfer Pricing Studies

Our team of capable transfer pricing professionals engages in the study of the following for enabling the domestic or international transfer pricing transactions

•     Detailed profile and business operations of the parties involved in the transaction

•     Particulars of the transaction

•     Functions, Assets and Risk Analysis

•     Selection and application of the most appropriate strategy

•     Research and analysis of the data collected from the databases, if required

•     Conclusion regarding the transfer pricing for each domestic or international transaction

Transfer Pricing Documentation

Our transfer pricing advisory services include transfer pricing documentation work based on the transaction requirement and the clients' inputs. We also aid in the determination of arm's length prices (ALP) and the selection of the most appropriate transfer pricing method.

We engage in a detailed analysis of the business profile of the client, industry of operation, and risk analysis of the transactions. We also get involved in the selection and characterization of entities and selection of the most appropriate method, which thereby leads to a final list of comparable companies. We ensure that the client remains in compliance with the transfer pricing laws and guidelines.

Transfer Pricing Policy

We facilitate the determination of the best transfer pricing policy for our clients after a complete review of the companies involved and the transaction, keeping in mind the applicable transfer pricing laws and regulations. Our transfer pricing services include help in drafting the planning document and an agreement between the associated enterprises.

We keep in check any transfer pricing risk that may arise in the future for both the companies. Our predictions and analysis of any unpredictable taxation risks serve as guidance to clients for checking the viability of their transfer pricing transactions. Our team is well-equipped to resolve complex transfer pricing transactions using our deep research and in-depth analysis.

Transfer Pricing Audit and Compliance

Globally, the scrutiny of transfer pricing activities has increased. We, at RAAC, help you develop such policies that ensure compliance with local country requirements, decrease transfer-pricing exposures for the future, and reduce any possibility of disputes related to the same.

We also sit with our clients and provide them round-the-clock support in preparing for the most appropriate audit response. As a part of our transfer pricing services, we ensure our clientele our all-time support in compliance with the transfer pricing regulations and during the auditing of such transactions.

Transfer Pricing Representation and Litigation

Our firm boasts of skilled and most experienced transfer pricing consultants to provide the best transfer pricing consulting services. They specialize in determining the most appropriate transfer pricing strategies and policies with no or reduced risks of international taxes. They are certified professionals in representing the clients in any issues raised by the authorities or tribunals. They have experience in representation before the Transfer Pricing Office (TPO), Dispute resolution Panel (DRP), or any other authorities.

Our transfer pricing litigation experts help the clients in litigation services before the Commissioner of Income Tax (Appeals) - CIT(A), Income Tax Appellate Tribunal (ITAT), High Courts and the Supreme Court of India. Our legal and tax experts have proven their expertise by successfully defending several clients against the appellate authorities in complex transfer pricing controversies.

Taxation of Expatriate

An expatriate is a person provisionally residing and employed in a different country while being citizen of his native land. The taxation of such expat employees requires a slightly modified computation than the tax computed for a normal resident employee of an Indian organization

Services RAAC offers-

Tax planning

Tax compliances

Obtaining a Certificate of Coverage and Income Tax Clearance Certificate

Calculating tax equalization

Assisting in the compliance procedure for claiming foreign tax credit (FTC)

Assessing tax residency status

Representing the expatriate in assessments, appeals, opinions, and litigation matters.

Filing of Form 15CA & CB

About Form 15CA and Form 15CB

Remittance of money by Indian residents to non-residents is a process of transferring money from India to a foreign country. This process is governed by regulations set by the Reserve Bank of India (RBI) and the government of India. Individuals and businesses can remit money abroad for various reasons such as education, medical treatment and maintenance of family members, business-related activities and investments. The process of remitting money abroad can be done through various channels such as banks, money transfer operators, and online platforms.

To remit money abroad, Indian residents will need to provide certain documents such as a PAN card, passport, and proof of purpose of remittance. They may also need to fill out specific forms such as Form 15CA and Form 15CB and provide information about the recipient, such as their name, address, and bank account details.

Form 15CA

Form 15CA, also known as the “Return for Furnishing Information with Respect to a Specified Transaction,” is a self-declaration form that is used to report details of a transaction with a non-resident, including the recipient’s name and address, the nature of the payment, and the amount being paid. It is mandatory to submit Form 15CA online on the e-filing portal of the Income Tax department for any specified transaction with a non-resident, which includes payments for professional services, royalties, fees for technical services, interest, etc.

The form is intended to provide the Income Tax department with information about transactions with non-residents, which are subject to TDS (Tax Deducted at Source) under the Indian Income Tax Act.

When a person or entity in India makes a payment to a non-resident, the payer is responsible for withholding a portion of the payment as tax and depositing it with the Income Tax department. The amount withheld is known as TDS (Tax Deducted at Source). The rate of TDS can vary depending on the nature of the payment and the provisions of the DTAA (Double Taxation Avoidance Agreement) between the countries.

Form 15CA has been divided into four sections, classified as follows:

Part A: Completing Part A of Form 15CA is mandatory if the amount being remitted is taxable under the Income Tax Act, 1961 and the total sum of such remittances does not exceed INR 5 lakhs in a financial year.

Part B: Completing Part B of Form 15CA is mandatory when the total sum of remittances exceeds INR 5 Lakh in a financial year and a certificate under section 195(2)/195(3)/197 of the Income-tax Act has been obtained from the Assessing Officer (with Nil or Lower rate certificate).

Part C: Filling out Part C of Form 15CA is necessary when the total sum of remittances exceeds INR 5 lakhs during a financial year and a certificate in Form No. 15CB from a Chartered Accountant has been obtained.

Part D: Part D is required to be filled where the remittance is not chargeable to tax under Income Tax Act.

It is crucial to ensure that the information provided in Form 15CA is accurate and complete. If the form is not submitted or if the information provided is incorrect, the payer may be subject to penalties and fines.

Form 15CB

Form 15CB is a form required to be filled and submitted by chartered accountants when an individual or a company wishes to remit money abroad. It is a certificate issued by the chartered accountant certifying that the proposed remittance is in accordance with the Income tax act and the rules and regulations prescribed under it.

In the case of specified transactions as mentioned in Part C for Form 15CA, the payer is required to obtain a certificate from a Chartered Accountant (CA) in the form of Form 15CB, certifying that the proposed remittance is not chargeable to tax in India or that the tax has been paid or will be paid at the lower rate, as specified in the DTAA or in the Indian Income Tax Act.

NRI Taxation Services

NRI stands for Non-Resident Indian and refers to a citizen of India who holds an Indian passport but resides outside of India for the majority of the year, typically for work or study. NRIs may maintain residences, properties, and businesses in India, but their primary residence is outside of India. An NRI is considered a non-resident for tax purposes and is subject to different regulations and laws than a resident Indian citizen. They also have certain economic and financial privileges in India, such as the ability to purchase property and invest in certain financial instruments.