International Taxation Advisory
PE, DTAA, equalisation, and substance for cross-border founders.
Plain language, then the law.
Residency, PE, DTAA and substance for cross-border founders, structured before money moves.
Govern-phase work is what lenders, regulators and future buyers read. Audits, ROC filings and forecasts are written to be reopened without you in the room. Document the price when you set it, not when you're asked — reconstructing arm's-length evidence after a notice is how adjustments happen.
The output is not a PDF dump. It is a file a future investor, banker, or officer can reopen without you in the room.

- 01
Facts
Residency, entity map and cash-flow routes documented first.
- 02
Risk
Permanent-establishment and substance tests per jurisdiction.
- 03
Treaty
DTAA benefits, withholding rates and TRC requirements mapped.
- 04
Structure
Holding, invoicing and ECB/FEMA positions designed before money moves.
- 05
File
15CA/CB support and assessment-ready documentation.
Lender trust
Audit-grade working papers behind every number you submit.
Regulator calm
ROC and tax filings on one calendar, no compounding surprises.
Diligence premium
Clean governance files price directly into valuation later.
- First DTAA question
- First cross-border invoice
- Related-party benchmarking
- PE/residency exposure
- Master file + local file documentation
- Multi-jurisdiction structuring
What's inside
Analysis
Hover to revealResidency, PE, and DTAA position
Documentation
Hover to revealBenchmarking and transfer pricing study
Filing
Hover to revealForm 3CEB and related compliance
Handover
Hover to revealWorking papers you can defend + calendar of next due dates
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