Structure. Optimize. Scale Efficiently.
The right corporate architecture determines your tax burden, regulatory exposure, and repatriation flexibility in India. Our network of 2,000+ senior bankers and structuring advisors designs holding structures, entity frameworks, and reorganization strategies that align with your global corporate objectives.
Why Corporate Structuring in India Demands Precision
Multi-Layered Regulatory Architecture
India's corporate structuring landscape spans Companies Act provisions, FEMA regulations, SEBI norms, and Income Tax Act requirements. A single structural misstep can trigger adverse tax consequences, regulatory penalties, or blocked repatriation pathways that persist for years.
DTAA and Transfer Pricing Complexity
With 90+ Double Taxation Avoidance Agreements, each carrying distinct treaty benefits, limitation-of-benefit clauses, and anti-abuse provisions, selecting the wrong jurisdiction for your holding structure can mean the difference between single-digit and double-digit effective tax rates.
Restructuring Without Triggering Tax Events
Mergers, demergers, slump sales, and share swaps each carry specific conditions under Indian tax law for tax-neutral treatment. Missing a single condition converts a tax-free reorganization into a fully taxable event.
Our Advisory Approach
Global Structure Assessment
We map your existing global corporate hierarchy, intercompany flows, IP ownership, and funding arrangements to identify structural inefficiencies, treaty mismatches, and regulatory risks specific to your India operations.
Jurisdiction and Entity Design
Our advisors evaluate holding jurisdiction options across 90+ DTAA countries, model effective tax rates under each treaty, and design the optimal entity architecture aligned to your operational and repatriation objectives.
Transfer Pricing Architecture
We design arm's-length intercompany pricing frameworks, benchmarking methodologies, and documentation structures that withstand scrutiny from Indian transfer pricing officers while preserving your intended profit allocation.
Reorganization Execution Planning
For restructurings, we architect the transaction with precise attention to appointed dates, consideration mechanics, NCLT timelines, and compliance conditions required for tax-neutral treatment.
Implementation and Ongoing Calibration
We coordinate with legal counsel, chartered accountants, and regulators to execute the structure, then monitor for legislative changes, treaty renegotiations, and judicial precedents that may require adjustments.
Global Structure Assessment
We map your existing global corporate hierarchy, intercompany flows, IP ownership, and funding arrangements to identify structural inefficiencies, treaty mismatches, and regulatory risks specific to your India operations.
Jurisdiction and Entity Design
Our advisors evaluate holding jurisdiction options across 90+ DTAA countries, model effective tax rates under each treaty, and design the optimal entity architecture aligned to your operational and repatriation objectives.
Transfer Pricing Architecture
We design arm's-length intercompany pricing frameworks, benchmarking methodologies, and documentation structures that withstand scrutiny from Indian transfer pricing officers while preserving your intended profit allocation.
Reorganization Execution Planning
For restructurings, we architect the transaction with precise attention to appointed dates, consideration mechanics, NCLT timelines, and compliance conditions required for tax-neutral treatment.
Implementation and Ongoing Calibration
We coordinate with legal counsel, chartered accountants, and regulators to execute the structure, then monitor for legislative changes, treaty renegotiations, and judicial precedents that may require adjustments.
What We Deliver
Holding Company Design
Optimal intermediate and ultimate holding structures across jurisdictions, modeled for withholding tax efficiency, capital gains treatment, and repatriation flexibility under applicable DTAAs.
Entity Architecture Advisory
Selection and design of the right Indian entity form - private limited, LLP, branch office, or project office - based on liability insulation, tax treatment, FEMA compliance, and exit flexibility.
Mergers and Demergers
End-to-end advisory on tax-neutral mergers and demergers under the Companies Act and Income Tax Act, including NCLT filings, appointed date selection, and post-scheme compliance.
Transfer Pricing Frameworks
Design of intercompany pricing policies, benchmarking studies, and contemporaneous documentation for management fees, royalties, technical services, and intercompany financing arrangements.
DTAA and Treaty Optimization
Treaty-by-treaty analysis across India's 90+ DTAA network to identify optimal routing structures, manage limitation-of-benefit risks, and secure favorable withholding tax rates.
Slump Sales and Asset Transfers
Structuring of business transfers as slump sales for favorable tax treatment, including valuation mechanics, undertaking definitions, and compliance with recent legislative amendments.
Structure-First, Not Tax-First
We design corporate architectures that serve your operational, governance, and commercial objectives first - then optimize for tax efficiency. This approach produces structures that withstand regulatory scrutiny and remain resilient through legislative changes.
Practitioner-Led, Not Theory-Driven
Our advisors have structured India entries and reorganizations from within banks, Big Four firms, and corporate treasury desks. They bring direct experience with NCLT proceedings, transfer pricing assessments, and treaty benefit claims.
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