Cross-border tax expertise, personally delivered. Across every category of international tax matter.
India's international tax framework has transformed — BEPS, tightened DTAA anti-avoidance, aggressive transfer pricing enforcement, and Pillar Two on the horizon.
NGA's international tax practice is built on rigorous analysis, commercially pragmatic advice, and seamless execution. Every engagement is led by CA Nikita Goel, who has spent her career on cross-border work.
90+ treaty network analysis, withholding tax optimisation, LOB / PPT analysis, MLI impact assessment.
TP documentation (Form 3CEB), ALP benchmarking, APA filings, BEPS Master File / Local File preparation.
Expat ITR, residency analysis, shadow payroll, DTAA salary claims, social security totalisation.
NRI returns, Schedule FA disclosure, FBAR / FATCA, exit and return-to-India tax planning.
CbCR, MLI impact, GloBE applicability analysis, Pillar Two readiness for in-scope groups.
DRP, ITAT, MAP, AAR representation for transfer pricing and treaty disputes.
Transfer pricing, dividend repatriation, treaty WHT — every related-party transaction has tax implications.
Whether liaison office, branch, or subsidiary — TP documentation, PE risk, DTAA management.
Foreign income, foreign assets, tax residency — the rules are unforgiving and the disclosures are aggressive.
International tax matters deserve a partner-CA leading the engagement — and that is how we structure our work.
Cross-border transactions trigger both. NGA handles them together — no coordination cost or risk.
Every position we take is defensible at DRP, ITAT, or MAP. We document with that horizon in mind.
A Double Taxation Avoidance Agreement is a bilateral treaty between India and another country that determines which country has the right to tax specific income. DTAAs typically reduce withholding rates on cross-border payments (dividends, interest, royalties, fees for technical services) and provide relief from double taxation via credit or exemption.
Form 3CEB is mandatory for any Indian entity with international transactions, or specified domestic transactions above ₹20 crore, with an associated enterprise. It must be filed along with the ITR by 31 October of the assessment year.
An NRI must file ITR in India if Indian-source income exceeds the basic exemption limit (₹2.5 lakh under the old regime, ₹3 lakh under the new). Even below this threshold, filing may be required to claim TDS refunds, carry forward losses, or if the NRI holds specified foreign assets under Schedule FA.
Domestic law rates under Section 195 range from 10% to 40% depending on the nature of income. Where a DTAA is available and the non-resident furnishes TRC and Form 10F, the treaty rate applies. Rates and beneficial-owner conditions differ by country.
Pillar Two of the OECD BEPS framework imposes a 15% global minimum tax on multinational groups with consolidated revenues above €750 million. India has committed to implementation. Groups below the threshold are unaffected; larger groups need to model GloBE income, top-up tax and CbCR obligations.