Service

International Tax Advisory

At AventaaGlobal, we help multinational businesses navigate cross-border tax matters with a clear objective: positions that are commercially aligned, technically defensible, and compliant across jurisdictions. Our advisory spans planning, transaction support, and risk management—helping reduce tax and compliance friction while improving certainty for global operations.

India is a key market for us, given our base, but our international tax advisory services are not limited to India. Where a process is jurisdiction-specific (for example, certain advance ruling mechanisms), we call it out explicitly.

Key Services We Offer

Treaty Advisory and Cross-Border Withholding Tax Support

International Tax Treaty Advisory (Multi-Jurisdiction)

We advise on the interpretation and application of tax treaties across jurisdictions to support effective planning and compliant outcomes, including:

residence vs source taxation analysis

characterisation of income (business profits, royalties, FTS/FIS, interest, dividends, capital gains)

withholding tax positions, relief procedures, and documentation alignment

treaty anti-abuse concepts (PPT/LOB-type rules where applicable), beneficial ownership, and treaty entitlement defensibility

OECD/BEPS Reforms and Anti-Avoidance Advisory

BEPS and MLI Impact Advisory (Global)

We support clients in evaluating and responding to evolving BEPS standards and MLI impacts (where relevant to the jurisdictions involved), helping strengthen structures and reduce controversy risk.

Anti-Avoidance and Substance Reviews (Global)

We assist with defensibility reviews around substance, anti-abuse provisions, and governance expectations—helping ensure cross-border arrangements remain robust under heightened scrutiny.

BEPS and GAAR-style Compliance Assistance

We advise on GAAR/anti-avoidance frameworks and related compliance considerations as they apply to cross-border structures and transactions, with a defensibility-first approach.

OECD Two-Pillar Solution Advisory (Pillar One and Pillar Two)

Pillar Two (GloBE / Global Minimum Tax) Readiness & Advisory

We support applicability assessment, impact modelling, data and governance readiness, and jurisdictional implementation tracking—helping groups plan and respond as rules evolve across countries.

Pillar One (Amount A) Developments & Impact Assessment

We assist with eligibility screening, high-level impact assessment, and preparedness planning as the Amount A framework progresses.

Pillar One (Amount B) Considerations

We advise on Amount B implications and practical adoption considerations across relevant jurisdictions, including operating model impacts and alignment of documentation and intercompany pricing positions. (Amount B interfaces closely with transfer pricing; where needed, we coordinate seamlessly with your Transfer Pricing service streams while keeping the overall international tax narrative consistent.)

Digital Economy Taxes and Unilateral Measures

Digital Economy Tax Developments (DST and Similar Levies)

We help businesses assess exposure and implications of digital economy taxes and unilateral measures across markets, and align cross-border tax positions to reduce uncertainty and dispute risk.

Cross-Border Structuring and Non-Resident Tax Advisory

01 Non-Resident Provisions and Cross-Border Tax Guidance

We advise on non-resident tax provisions across jurisdictions, including sector-specific considerations (e.g., shipping/maritime where relevant), and support withholding and reporting positions.

02 Cross-Border Transaction Advisory

We provide transaction-level advisory for inbound/outbound arrangements, financing flows, service models, and cash repatriation—aligned with local rules and treaty positions.

Investment Treaty and Cross-Border Protection Considerations

Investment Treaty Consulting

We help businesses understand and evaluate investment treaty considerations relevant to their investment footprint, particularly where treaty-based protections and long-term certainty are important.

(Where issues are primarily legal/regulatory, we coordinate so the overall approach remains consistent and defensible.)

Advance Ruling / Advance Guidance Support

01 Advance Guidance Support (Jurisdiction-Specific)

We support applications and submissions for advanced guidance mechanisms where available, helping businesses obtain clarity on complex cross-border tax positions.

02 India-specific (where applicable)

Support for preparing and filing applications before the relevant advance ruling forums in India, including fact framing, technical positions, and submission quality.

UN Tax Convention Developments

UN International Tax Cooperation (Monitoring & Impact Insights)

We monitor evolving UN tax convention/protocol developments and provide impact assessments and executive insights for multinational groups as the framework progresses.

Outcome

Our international tax advisory is designed to help you reduce tax and compliance friction, improve certainty for cross-border operations, and support global expansion with positions that hold up under regulatory scrutiny.