International Tax — Cross-Border Precision

India has Double Taxation Avoidance Agreements (DTAAs) with over 90 countries. These treaties override domestic tax law where they provide more beneficial treatment — making DTAA analysis the first step in any cross-border tax planning exercise.

The Income Tax Act governs taxation of foreign income earned by Indian residents (Section 5), Indian-source income of non-residents (Section 9), and foreign tax credits (Section 90/91). Transfer pricing provisions (Sections 92–92F) mandate arm's-length pricing for all international transactions between associated enterprises, with penalties of up to 2% of the transaction value for non-compliance.

• DTAA Analysis & Planning — Treaty eligibility, beneficial ownership, limitation of benefits and tax residency certificate advisory across 90+ jurisdictions
• Withholding Tax Optimisation — Structuring payments (royalties, FTS, interest, dividends) to minimise Indian WHT under applicable treaties
• PE Risk Analysis — Assessing and mitigating Permanent Establishment exposure for foreign companies operating in India
• Transfer Pricing — Documentation, benchmarking studies, APA applications and TP dispute resolution
• NRI Tax Planning — Residency determination, RNOR status planning, Schedule FA compliance, LRS advisory
• Inbound Investment Structuring — Optimal holding structures for foreign investment into India
• Outbound Investment Advisory — Tax-efficient structuring for Indian investment abroad; ODI compliance

Blackthorn operates on a transparent, upfront fee structure. Every engagement begins with a clear fee estimate — no surprises, no hidden charges. The ranges below are indicative; your specific matter will be quoted precisely after the initial consultation.