Direct tax – Associate | Pune

Role & Responsibilities

M&A

• Structuring/advisory on deals from tax perspective and foreign exchange control perspective – FEMA, domestic tax law, DTAAs, stamp duty and other allied law.
• Drafting and review of deal documents including term sheets, loan agreements, SPAs, disclosures, BTA, merger scheme, reps and warranties, etc.
• Handholding in conceptualizing the deals with specific focus on India entry/ exit strategy, favourable holding jurisdiction, tax efficiency and commercial rationale
• Advisory on possible structuring through the IFSC Gift city.
• Front ending/ liaising with various stakeholders including AD Banker.
• Undertaking health check and preparing due diligence reports.

International Tax and FEMA advisory

• Advisory assignments on international tax issues including PE, profit attribution, business connection, expat tax, ESOPs, indirect transfer, POEM, capital repatriation, royalty, FTS, broadcasting rights, tax transparent entities, etc.
• Effective tax rate (ETR) planning analysis for an Indian promoter held group with 190+ entities.
• Advisory on FEMA and assistance in compounding application.
• Assistance in lower withholding applications, condonation applications, assessments,
• appeals at all levels. Engaging with Senior Counsels, preparing synopsis and briefing.

Experience 0-3 years

Qualification

CA/LLB