International Taxation Services

Home  /  Our Services  /  International Taxation Services

Cross-Border Tax

International Taxation Services

Cross-border tax is never just about filing correctly — it requires treaty interpretation, technical precision and a clear read on how India's international tax framework applies to your specific situation. LEAPRO supports businesses, foreign entities and individuals navigating inbound investment structuring, treaty benefit claims, foreign tax credits and expatriate taxation, backed by experienced professionals who work with this framework daily.

90+
Tax treaties India holds, each with its own provisions
15CA/CB
Certification handled for every category of remittance
2%
Equalisation Levy compliance for digital services
TRC
Guidance on securing residency certification for treaty claims

Who This Is For

  • Foreign corporations earning Indian-source income — royalties, technical fees, interest, dividends
  • Multinational groups with Indian subsidiaries, branches or liaison offices needing cross-border structuring
  • Cross-border investors, including venture capital, private equity and institutional funds
  • Foreign nationals and expatriates working in India requiring residency determination and treaty benefits
  • Indian companies making outbound payments to non-residents that require withholding compliance
  • Businesses with overseas operations claiming foreign tax credit on Indian returns
  • Companies navigating Equalisation Levy on digital services and e-commerce transactions

What Our International Tax Services Cover

DTAA Advisory

  • Applicability review across India's 90+ tax treaties
  • Most Favoured Nation clause and treaty shopping risk analysis
  • Principal Purpose Test and Limitation of Benefits assessment under MLI

Form 15CA / 15CB

  • Preparation and filing for every category of foreign remittance
  • CA certification supporting treaty benefit claims
  • Coordination with FEMA compliance for cross-border payments

Withholding Tax Advisory

  • Applicable rate determination under domestic law and treaty provisions
  • Advisory on royalty, technical fee, interest and professional fee payments
  • TDS compliance, challan generation and Form 26AS reconciliation

Foreign Tax Credit

  • Form 67 review and filing for tax credit on income taxed abroad
  • Consolidation of overseas tax payment documentation
  • Relief through credit method, exemption method or advance pricing agreements

Expatriate Taxation

  • Residency determination based on physical presence and visa status
  • DTAA benefit claims for salary, allowances and perquisites
  • Advisory on tax equalisation and gross-up calculations

Treaty Certification Support

  • Form 10F preparation for claiming DTAA benefits
  • Support securing Tax Residency Certificates from the home country
  • Form 10FB certification for reportable accounts under CRS

PAN for Foreign Entities

  • PAN application support for non-resident companies, partnerships and individuals
  • Documentation preparation covering identity, address and home-country registration
  • Follow-up with the Income Tax Department for allotment and error correction

Equalisation Levy Advisory

  • Compliance support for the 2% levy on e-commerce operators and digital services
  • Advisory on scope, exemptions and reporting obligations under Finance Act provisions
  • Quarterly return filing and payment coordination

Cross-Border Tax Mistakes We Commonly Fix

Common Mistake What Goes Wrong How LEAPRO Prevents It
Withholding at the domestic rate without checking DTAA 10% TDS applied on royalty when the treaty rate is actually 5%, and the overpayment is never recovered Treaty analysis before payment, with the lower rate applied through proper Form 15CA/15CB filing
Missing Form 15CA/15CB before remittance Payment goes abroad without the forms filed — a compliance violation even when the tax itself was correct Mandatory form-filing checklist built into the payment approval workflow
No Tax Residency Certificate from the payee Treaty benefit claimed, but the TRC was never obtained from the foreign company's tax authority TRC requirement verified upfront, with follow-up well before year-end
Foreign tax credit claimed without Form 67 Overseas tax paid is shown in the return, but Form 67 was never filed before the due date Form 67 filing tracked against the ITR due date with supporting documentation prepared in advance
Wrong payment classification Professional fees get classified as Fees for Technical Services, pulling in the wrong withholding rate Payment nature analysis with a make-available clause check against the applicable DTAA

Why Choose LEAPRO for International Tax

What Sets Us Apart What It Means for You
90+ treaty knowledge We've worked across India's tax treaties with the US, UK, Singapore, Mauritius, Netherlands, Japan and others
Form 15CA/15CB specialists CA certification under Form 15CB for treaty claims is core to what we do — we handle a high volume of these annually
Chennai-based, global reach Headquartered in Chennai, serving foreign companies worldwide with India tax obligations
Expatriate tax experience Years of experience across employment, business and consultancy visa categories
MLI and BEPS aligned We track Multilateral Instrument amendments and BEPS action plan impacts on India's treaty network
Integrated with domestic tax Cross-border positions are coordinated with ITR filing, GST and transfer pricing rather than handled in isolation
Foreign company specialists Deep experience with WOS, branch offices, liaison offices and non-resident taxation generally

Frequently Asked Questions

A Double Taxation Avoidance Agreement stops the same income being taxed twice, in two different countries. India holds treaties with over 90 countries, offering reduced withholding rates, exemptions and tax credit relief depending on which one applies to you.
Form 15CA is required whenever money is remitted to a non-resident. Form 15CB is a Chartered Accountant certification, required in many cases, confirming tax compliance and treaty applicability. We prepare both and calculate the correct withholding tax alongside them.
It depends on residential status. Residents are taxed on global income; non-residents are taxed only on India-sourced income. DTAA provisions may reduce this further. We determine status first, then work out where treaty benefits genuinely apply.
Yes — for example, royalty income might be taxed at 10% under domestic law but only 5% under the India-Singapore treaty. Claiming that benefit requires a Tax Residency Certificate, Form 10F, and proper Form 15CA/15CB filing to back it up.
If income is taxed both abroad and in India, credit for the foreign tax paid can be claimed via Form 67, filed before the ITR due date along with proof of overseas payment and income reporting.
A TRC is issued by the home country's tax authority to certify tax residency for treaty purposes, and it's required to claim reduced withholding rates or exemptions under DTAA. We guide clients through obtaining one and using it correctly in India.
It's a 2% levy on e-commerce operators and consideration for digital services, applying to non-resident companies without a permanent establishment in India. We handle the compliance and quarterly filing that comes with it.
It's possible but not automatic. If the treaty rate was 5% but 10% was withheld, the non-resident needs to file an Indian return claiming the refund, supported by proper documentation. We handle this process end to end.

Structuring a Cross-Border Payment or Investment?

Speak with our international tax team before the transaction, not after.

CONNECT TEAM