Our Services

International Tax & Global Tax Certainty

Helping businesses manage cross-border tax, compliance, and transfer pricing with strategic precision and efficiency.

Enabling Cross-Border Growth with Certainty, Compliance & Strategic Control

In an increasingly interconnected global economy, businesses face complex international tax challenges driven by evolving regulations, BEPS initiatives, transfer pricing scrutiny, and aggressive tax enforcement across jurisdictions. Achieving global tax certainty is no longer optionalβ€”it is critical for sustainable cross-border operations, investment planning, and risk management.

At PGAS & Associates, we provide integrated International Tax and Global Tax Certainty advisory services to Indian and multinational enterprises. Our approach combines technical tax expertise, transfer pricing insights, treaty interpretation, and dispute resolution strategies to help businesses manage cross-border tax risks with clarity and confidence.

We assist clients in structuring, documenting, defending, and resolving international tax positionsβ€”ensuring compliance while minimizing uncertainty, double taxation, and litigation exposure.

Our International Tax & Global Tax Certainty Services

1. International Tax Advisory & Structuring

We advise on tax-efficient structuring of cross-border transactions, investments, and operations, aligned with commercial objectives and regulatory requirements.

Key focus areas include:

  • Cross-border transaction structuring and tax optimization
  • Treaty interpretation and application under Double Taxation Avoidance Agreements (DTAAs)
  • Withholding tax advisory on royalties, fees for technical services, interest, and dividends
  • Permanent Establishment (PE) risk assessment and mitigation
  • Profit attribution and source-based taxation analysis
  • FEMA and Income-tax alignment for inbound and outbound investments

Our advisory ensures that tax positions are commercially defensible, compliant, and sustainable across jurisdictions.

2. Transfer Pricing & Global Value Chain Alignment

Transfer pricing is central to global tax certainty. We support multinational groups in designing and implementing transfer pricing frameworks that reflect economic reality and withstand scrutiny.

Our services cover:

  • Transfer pricing policy design and implementation
  • Global value chain and FAR (Functions, Assets, Risks) analysis
  • Economic benchmarking and arm’s length pricing analysis
  • Three-tier documentation (Local File, Master File, CbCR)
  • Form 3CEB, Form 3CEAA (Part A & B), and Form 3CEAB compliances
  • Intercompany pricing for goods, services, intangibles, and financing arrangements

We help ensure pricing consistency across jurisdictions while aligning with BEPS and OECD guidelines.

3. Advance Pricing Arrangements (APA) & Tax Certainty Mechanisms

APAs are a cornerstone of global tax certainty, offering long-term assurance on transfer pricing outcomes.

We provide end-to-end support for:

  • Unilateral, bilateral, and multilateral APA applications
  • Rollback coverage for prior years
  • Preparation of economic and legal documentation
  • Negotiations with CBDT and foreign tax authorities
  • Post-APA compliance and monitoring

Our structured approach helps clients secure certainty for up to nine years, significantly reducing future litigation risk.

4. Mutual Agreement Procedure (MAP) & Double Taxation Resolution

Cross-border disputes often lead to double taxation. The MAP framework under India’s extensive DTAA network provides a critical dispute resolution mechanism.

We assist clients in:

  • Evaluating MAP eligibility and strategic suitability
  • Preparing position papers and economic analyses
  • Coordinating with Indian and foreign competent authorities
  • Supporting implementation of MAP resolutions

Our objective is to eliminate double taxation, protect global profits, and restore certainty in international tax positions.

5. International Tax Litigation & Controversy Management

With increased audits and aggressive positions by tax authorities, proactive controversy management is essential.

We support clients during:

  • Transfer Pricing Officer (TPO) audits and assessments
  • Proceedings before DRP, CIT(A), ITAT, and High Courts
  • Strategy formulation for cross-border tax disputes
  • Technical submissions, economic defenses, and expert support

Our experience ensures that international tax disputes are handled with strategic foresight and technical precision.

6. Global Tax Risk Assessment & FIN 48 Assistance

Uncertain tax positions can materially impact financial statements and investor confidence.

Our FIN 48 and global tax risk services include:

  • Identification of uncertain international tax positions
  • Quantification of tax exposures and probability assessments
  • Documentation aligned with audit and disclosure standards
  • Support during statutory and internal audits

We enable management to take informed, transparent, and defensible positions in financial reporting.

7. Transfer Pricing & International Tax Valuation Services

Valuation plays a critical role in cross-border restructurings and global tax compliance.

We provide:

  • Valuation of shares, businesses, and intangibles
  • Valuations for transfer of IP, business restructuring, and group reorganizations
  • Alignment with arm’s length principles, FEMA, and Income-tax regulations
  • Robust financial modeling integrated with TP methodologies

Our valuations are designed to be independent, defensible, and regulator-ready.

8. BEPS Alignment & Documentation Re-engineering

The BEPS framework has reshaped global tax transparency and enforcement.

We assist multinational groups in:

  • Reviewing existing transfer pricing and tax documentation
  • Identifying gaps and inconsistencies under BEPS Action 13
  • Re-aligning policies, value chains, and documentation
  • Enhancing audit defensibility and reducing global tax risk

Why PGAS & Associates

Contact Us

Partner with PGAS & Associates to achieve global tax certainty.

Whether you are expanding internationally, managing cross-border risks, or resolving complex tax disputes, our team provides the clarity and confidence needed to operate seamlessly across jurisdictions.

Contact us today to discuss your international tax and global tax certainty requirements.