Transaction Tax Services

It involves re-arranging of a company/group, aimed at organic and inorganic growth, fund raise, cost reduction and higher efficiency and profitability.

Our corporate restructuring advisory services seek to address issues related to disposal or spin-off of unviable businesses/surplus assets, streamline group structure through consolidation of companies, enter into joint ventures, share profit with shareholder/investors, achieve cost efficiencies. It also includes other forms of internal group restructuring or financial reengineering such as capital reduction, share-buyback, segregation/integration of businesses, listing and delisting, IPO offers, strategies for optimising group cost, etc.

Cross border investments in India by foreign investors and investment by Indian investors outside India have been consistently growing over the past decade, necessitating focussed attention on compliance with the applicable foreign exchange and tax regulations.

Cross border transaction advisory services include advisory on inbound/outbound business, investment and acquisition structuring, advisory on direct public listing overseas or through special purpose acquisition companies, investment holding and funding mechanisms for proposed investment/acquisitions and business model, including IP ownership review and advisory from a tax optimisation perspective.

We provide a spectrum of tax advisory services to corporates and private equity investors across sectors. These services include identifying deal-specific tax risks and opportunities, highlighting contingencies and providing assistance in identification of negotiation points from a tax perspective.

Deal advisory includes a spectrum of services such as vendor/buy-side tax due diligence, buy-side/sell-side transaction structuring, review of transaction documents, assistance in finalisation of tax warranties and indemnities and tax and regulatory compliances to be undertaken in the course of the transaction.

Investment or acquisition of distressed assets in India by corporates is a recent and widely used opportunity. We assist buyers and investors in evaluating and structuring various investment opportunities and strategies.

Our offerings include advisory services in relation to due diligence, advisory on bid preparation and acquisition of distressed assets, and entities covered under the Insolvency & Bankruptcy Code, 2016, deal execution support and post-acquisition structuring, e.g., consolidation.

We help clients develop a transaction (both investment and exit) strategy basis the tax and regulatory implications of the proposed transaction/deal. Our teams also assist in post-acquisition tax assessment to identify and minimise tax inefficiencies and optimise tax implications on returns and future exit.

We provide end-to-end assistance to start-ups. This incudes conceptualisation of investment/business structure from a tax and regulatory perspective, entity options, setting up (evaluating and supporting on available tax exemptions), securing registration with various regulatory authorities (DIPP, etc.), planning and executing stock-based rewards and conducting vendor due diligences to facilitate fund raise and due diligences and providing structuring advisory for acquisition.

To execute any organic or inorganic structuring, we assist our clients with end-to-end implementation and project management of the desired structure. This includes merger (NCLT/fast0track merger), demerger/hive-off, capital reduction, buyback, listing, delisting, etc. It also includes liaising with lawyers and other advisors and providing assistance in obtaining requisite statutory approvals (NCLT, RBI, SEBI, DIPP, etc.) and undertaking pre/post transaction compliances and filings.

Promoter shareholding re-alignment is a complex process for creation of an efficient and streamlined promoter shareholding structure. It is aimed at creating an ownership structure, which is both tax efficient, regulatory compliant and enable preservation and enhancement of promoter wealth. Promoter shareholding structuring is usually undertaken before a fund raise.

Further a streamlined promoter structure also enables intergenerational transfer of wealth.Structuring of promoter holding would have to be specific to the dynamics and objectives of the promoter family. Hence, the solutions for the same are also customised and engineered as per the specific needs of each case.

We provide advisory on consolidation and realignment of promoter holding structures and help in implementing the same through a combination of restructuring tools, mergers, demergers, buy back and capital reduction.