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International Taxation Services

Navigating cross-border tax complexity with precision — from DTAA analysis and foreign tax credits to FEMA compliance and BEPS-aligned structuring.

  • DTAA Advisory
  • FEMA Compliance
  • NRI Taxation
  • Foreign Tax Credits
  • BEPS & Pillar Two
  • GCC Structuring

International Taxation Services

Welcome to PGA & Co. Chartered Accountants (PGACA) — your trusted advisor for International Taxation. As India's economy deepens its global integration, cross-border transactions, overseas investments, and foreign income streams create complex tax obligations. Our team specialises in helping individuals, businesses, and multinationals stay compliant while optimising their international tax position.

International taxation governs how income, profits, and capital gains earned across different countries are taxed. For Indian residents with foreign income, NRIs with India-sourced income, foreign companies operating in India, and Indian businesses expanding abroad — the rules span the Income Tax Act 1961, DTAAs, FEMA 1999, and evolving OECD/BEPS frameworks.

At PGA & Co., we go beyond mere compliance. We structure transactions, advise on treaty positions, and design tax-efficient holding structures that protect your interests across jurisdictions — while keeping you fully compliant.

Our International Taxation Services

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DTAA Advisory & Treaty Analysis

Interpretation and application of India's 90+ tax treaties. We advise on residency, beneficial ownership, treaty shopping risks, and withholding tax relief under applicable DTAAs.

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Foreign Tax Credit (FTC) Claims

Computation and filing of FTC under Rule 128 of the Income Tax Rules. We ensure maximum credit for taxes paid abroad, preventing double taxation on your global income.

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FEMA & RBI Compliance

End-to-end advisory on FEMA — ODI, FDI, LRS remittances, compounding of contraventions, and RBI filing requirements for overseas transactions.

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NRI & Returning Indian Taxation

Residency determination, tax planning for NRIs, RNOR status optimisation, taxation of foreign assets on return to India, and FEMA-compliant repatriation strategies.

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Foreign Company & PE Advisory

Tax advisory for foreign companies on Permanent Establishment exposure, business connection tests, attribution of profits to PE, and managing PE risk in India.

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BEPS & Pillar Two Compliance

BEPS Action Plan compliance, Country-by-Country Reporting (CbCR), Master File / Local File documentation, and readiness for the OECD Pillar Two global minimum tax.

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Cross-Border Structuring

Tax-efficient international holding structures, inbound/outbound investment planning, GCC setup advisory, and restructuring of overseas operations.

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International Tax Litigation & MAP

Representation before Indian tax authorities in cross-border disputes, Mutual Agreement Procedure (MAP) filings, and Advance Pricing Agreements.

Who We Serve

  • NRIs with India-sourced income or assets
  • Indian individuals with foreign investments
  • Multinational corporations operating in India
  • Indian companies expanding overseas
  • Foreign companies with Indian subsidiaries
  • HNIs with global asset portfolios
  • Startups seeking overseas incorporation
  • Professionals on cross-border assignments

Why Choose PGA & Co. for International Tax?

International tax is one of the most specialised areas of practice. Our team actively tracks OECD developments, CBDT circulars, and judicial precedents to give you advice that is current, accurate, and actionable.

50+
India's active tax treaties covered
12+
Years of international tax practice
100+
Cross-border clients served

Frequently Asked Questions

What is a Double Taxation Avoidance Agreement (DTAA)? ▼
A DTAA is a bilateral treaty between two countries to prevent the same income being taxed twice. India has signed over 90 such treaties. The treaty determines which country has taxing rights, at what rates, and provides relief mechanisms such as exemption or foreign tax credit.
I am an NRI returning to India permanently. What are my tax obligations? ▼
When you return, your status changes from NRI to Resident, then from RNOR to ROR. During RNOR period (typically 2–3 years), your foreign income generally remains outside Indian tax. Once ROR, global income becomes taxable in India. Proper planning before return — repatriation, restructuring of investments — can significantly reduce your tax burden.
Does my Indian company have Permanent Establishment (PE) risk abroad? ▼
Yes, if your company has employees, agents, or operations abroad, PE exposure may arise — creating unexpected tax liabilities in the foreign country. We assess your business model and contracts to identify and mitigate PE risk before it becomes a dispute.
What is the Liberalised Remittance Scheme (LRS) and its tax implications? ▼
Under RBI's LRS, resident individuals can remit up to USD 250,000 per year for overseas investments, education, and travel. TCS applies on remittances above INR 7 lakh for most LRS purposes. Income from LRS investments is also taxable in India. We ensure your LRS remittances are structured to be fully compliant and TCS-efficient.
What is BEPS and does it affect Indian businesses? ▼
BEPS (Base Erosion and Profit Shifting) is an OECD initiative to prevent multinationals from exploiting gaps in tax rules. India has implemented BEPS measures including CbCR, revised PE rules, GAAR, and MLI modifications to DTAAs. If your group revenue exceeds INR 5,500 crore, CbCR filing is mandatory. We help groups assess BEPS exposure and meet all compliance requirements.

Ready to resolve your international tax challenges?

Speak with our experts — first consultation is complimentary.

Contact Us Today →
Quick Enquiry
What is International Tax?
Scope
Rules governing taxation of income that crosses national borders — foreign income of residents and Indian income of non-residents.
Key Laws
Income Tax Act 1961, DTAAs, FEMA 1999, OECD BEPS framework, and the Multilateral Instrument (MLI).
Why It Matters
Without proper advice, the same income can be taxed in two countries. Penalties under the Black Money Act are severe.
Our Services
Contact PGA & Co.
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Office
SCO 18, Top Floor, Sector 20-D, Chandigarh 160020

PGA & Co. Your No.1 Chartered Accountant Firm in Chandigarh. Trusted for precision, accredited expertise, and tailored financial solutions.

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Phone

86998-87200

Email

info@pgaca.in

Location

SCO 18, Top Floor,
Sector 20-D, Chandigarh, India 160020