← Expertise
International Tax
Cross-border tax structuring, treaty positions and transfer pricing for inbound and outbound clients.
What we do
We counsel multinational groups, foreign investors and Indian clients with international footprints on cross-border tax — treaty interpretation, withholding, permanent establishment, transfer pricing and BEPS-aligned structuring.
Who we advise
Multinationals, foreign strategic and financial investors, NRIs and Indian groups with overseas operations or holdings.
Typical issues
- Cross-border investment and holding structures
- Tax treaty interpretation and withholding analysis
- Permanent establishment and characterisation questions
- Transfer pricing strategy, documentation and disputes
How Cornellia approaches this
International tax is where commercial structure meets sovereign claim. We design for both — and defend the design.