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International Tax
Disputes

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.

Transfer Pricing Disputes

TP litigation and defense

✓TP adjustments
✓Penalty defense
✓APA litigation
✓Safe harbour
✓Secondary adjustments
✓MAP proceedings

DTAA Matters

Tax treaty disputes

✓Treaty interpretation
✓Residence certificate
✓TRC disputes
✓Withholding tax
✓PE disputes
✓Capital gains

Advance Pricing Agreement

APA applications and renewal

✓Unilateral APA
✓Bilateral APA
✓Rollback provisions
✓Renewal
✓Compliance
✓Monitoring

POEM & PE

Place of Effective Management disputes

✓POEM determination
✓PE disputes
✓FE/FI characterization
✓Royalty/FTS issues
✓Agency PE
✓Virtual PE

Why Choose ANYTAX?

✓International tax specialists
✓Treaty expertise
✓Transfer pricing experience
✓Global perspective
✓Multilateral coordination
✓Effective resolution

International Tax Issue?

Expert resolution of cross-border tax disputes

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