TP, PE, treaty withholding, MAP/APA, equalisation levy — OECD/MLI-aware defence.
International tax disputes have grown with BEPS, India's MLI position, equalisation levy, and treaty Principal Purpose Tests. Our team handles transfer pricing adjustments, PE attribution, treaty withholding on dividends/royalties/FTS, MAP, APA rollbacks, and equalisation levy disputes for digital service providers.
TP litigation and defense
Tax treaty disputes
APA applications and renewal
Place of Effective Management disputes