Providing tax advisory in relation to selection of optimal structure and jurisdiction for overseas direct investment
Understanding the objective for investment, understanding the exit strategy, interpretation of Double Tax Avoidance Agreement/ Tax Treaty, analysing different modes of repatriation of monies and exit convenience. Also understand the frequency of such repatriations or exits.
1. Business plan for investment 2. Investment mechanics and amounts 3. Organisation structure and hierarchy 4. Financials of HoldCo and its subsidiaries 5. RBI Reporting and filings made in last 15 months 6. Any tax advisory memo relevant to the decision