How to Choose an International Tax Advisory Firm in India: A Buyer’s Checklist

Your group needs India-specific calculations for Pillar Two. The parent company’s project team has spent five months working in India, raising questions about whether its activities have created a permanent establishment (PE). A change to a tax treaty could also affect an existing group structure.

These issues require someone who understands Indian tax law and can explain how the Indian position affects the rest of the group. 

A firm that handles domestic compliance well may have less experience with treaty interpretation, cross-border tax calculations or disputes before the Indian tax authorities.

If you lead tax for an Indian subsidiary or a regional business, you need to know whether a prospective international tax adviser can handle these issues. 

The following checklist will help you assess an International Tax Advisory Firm: its experience, the people who would work on your account and the support you can expect.

TL;DRAn international tax advisory firm for India has to cover the join between Indian law and your group’s other jurisdictions, as well as each side on its own.Seven checks: treaty network, Pillar Two readiness, permanent establishment (PE) risk, inbound and outbound structuring, transfer pricing coordination, cross-border dispute resolution, and sector experience.Three changes in 2026 make the checklist time-sensitive: the Income-tax Act, 2025, the OECD side-by-side package for Pillar Two, and the India-Mauritius treaty protocol that entered into force on 10 August 2026.Ask each firm for evidence on every item, and compare engagement models before you compare fees.

Why International Tax Is Different From Domestic Tax

Domestic tax compliance focuses on filing returns correctly, reporting income and meeting deadlines. International tax advisory deals with questions that cross borders: which country can tax a payment, whether a foreign company has a taxable presence in India, and how the resulting liability affects the wider group.

Take for example, a royalty paid by an Indian subsidiary to its overseas parent. The payment raises four connected questions:

• Transfer Pricing: Is the royalty rate at arm’s length, given the rights granted and the benefits received?
• Withholding Tax: What rate applies under Indian law and the relevant tax treaty?
• Permanent Establishment: Do the foreign company’s activities in India create additional tax exposure?
• Pillar Two: How does the payment affect the group’s effective tax rate and potential top-up tax?

Each question requires different evidence and analysis. The treaty’s wording, the group’s legal structure, the activities performed in India and the terms of the intercompany agreement can all affect the outcome.

A decision that works for Indian withholding tax may still create a transfer pricing issue or affect the group’s minimum tax calculations.

The consequences can go beyond an additional tax demand. A disputed payment may lead to double taxation, prolonged negotiations between tax authorities or the need to amend the group’s reporting position in another country.

This is why a multinational’s India tax head needs a tax adviser who understands how domestic rules interact with treaties, transfer pricing and international tax frameworks. 

When assessing an international tax advisory firm, ask how it coordinates advice across jurisdictions, handles disagreements between local and global tax positions, and documents the reasoning behind its recommendations.

Ensure your Indian tax position can withstand scrutiny and align with the group’s wider tax strategy.

The Buyer’s Checklist

Each item below is something you can ask a firm to demonstrate. 

Not every firm you consider needs to cover all seven items in-house. A firm that is strong in India but does not advise in your parent’s jurisdiction can still be a sound choice if it has a clear way of working with your other advisers. 

Items 5 and 6 test that directly. What you should not accept is a firm that cannot say who owns the connection between the pieces.

While you read the checklist items, identify which areas are the most important to your group. 

If your group has had a team working in India for an extended period, pay close attention to PE risk. If your group falls within the scope of Pillar Two, prioritise item 2. If a consultant falls short on two or more of your highest-priority areas, consider other firms or bringing in a specialist for those specific needs.

Checklist Item 1: Cross-Border Treaty Network

A firm’s treaty network is useful when its advisers understand the treaties relevant to your transactions and can work with tax experts in your parent company’s country.

These treaties govern issues such as permanent establishment, royalties, fees for technical services, capital gains and relief from double taxation.

The applicable treaty must also be checked against modifications under the Multilateral Instrument (MLI) and any subsequent protocols. Relying on the original treaty text alone can lead to incorrect conclusions.

The India-Mauritius treaty shows why advisers need to keep up with changes. A protocol signed in 2024 introduced a principal purpose test (PPT), which can deny treaty benefits in certain cases where obtaining those benefits was one of the main reasons for an arrangement.

What to Check When Assessing a Firm

• A redacted treaty analysis for a similar transaction.
• How the firm tracks treaty amendments and changes under the Multilateral Instrument (MLI).
• A named contact in your parent company’s country who has worked with the Indian team on a cross-border case.

A list of international offices is not enough. Look for evidence that the firm has handled cross-border tax questions and can explain its conclusions in writing.

Checklist Item 2: BEPS 2.0 Pillar Two Readiness

For multinational groups with consolidated annual revenue of at least €750 million, Pillar Two can create additional tax and reporting obligations. 

An Indian subsidiary’s financial results may affect the group’s jurisdictional effective tax rate and any top-up tax liability.

India’s tax rules, available incentives and accounting figures all affect the calculation of the effective tax rate. 

Your adviser should understand the GloBE rules, including the Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR) and Qualified Domestic Minimum Top-up Tax (QDMTT), and explain how they apply to your Indian entity.

What Evidence Should You Request?

• A sample GloBE effective tax rate calculation for India.
• An explanation of how Indian tax incentives affect the calculation.
• Details of the financial and tax data required from your Indian entity.
• Evidence of coordination with your group’s global Pillar Two team.
• An update on applicable safe harbours and India’s current legislative position.

Be cautious of firms claiming Pillar Two expertise without showing their modelling approach or supporting workpapers. You need a team that can explain the numbers and identify potential exposure.

Checklist Item 3: PE Risk Assessment Capability

A permanent establishment (PE) in India can expose a foreign company to Indian tax on profits attributable to its Indian presence. 

Common risk areas include employees working at Indian sites for extended periods, secondment arrangements, contract negotiations conducted by Indian personnel and service activities that cross treaty-specific time thresholds.

The outcome depends on the applicable tax treaty and the facts. 

A secondment arrangement, for example, needs to be assessed against employees’ actual responsibilities, reporting lines, decision-making authority and day-to-day activities. The wording of the agreement alone may not settle the question.

What Evidence Should You Request?

• A sample PE risk questionnaire covering employee activities, travel days and reporting structures.
• A redacted risk assessment showing how the firm reached its conclusion.
• An explanation of how it calculates profits attributable to a potential PE.
• Advice on the next steps if a risk is identified, including registration, filing obligations or changes to the operating arrangement.

A capable adviser should connect the treaty provisions with the facts on the ground. Be cautious if the firm gives a definitive answer before reviewing your contracts, secondment arrangements and actual working practices..

Checklist Item 4: Inbound and Outbound Structuring Experience

A capable international tax adviser should understand both foreign investment into India and Indian businesses expanding overseas. Each involves tax, regulatory and commercial decisions that need to work together.

Inbound structuring may involve choosing between an Indian subsidiary, branch or LLP, deciding how to fund operations, and assessing treaty access, withholding tax and interest deduction rules. 

Outbound structuring requires advice on overseas investment under FEMA, foreign tax credits, holding jurisdictions and the tax treatment of future exits.

Experience in one direction does not guarantee expertise in the other. Ask how the firm compares alternative structures, assesses commercial substance and accounts for treaty changes.

What Evidence Should You Request?

• A redacted structure chart showing tax and regulatory considerations.
• Examples of alternative structures and the reasons for the recommendation.
• Details of how tax, FEMA and legal advice are coordinated.
• An exit analysis covering capital gains and treaty provisions.

The International Tax Advisory Firm should be able to assess the structure from initial investment through ongoing operations, repatriation and exit, identifying tax and regulatory risks at each stage.

Checklist Item 5: Transfer Pricing Coordination

International tax advice and transfer pricing documentation need to support the same position. 

The pricing of a royalty, management fee or intercompany loan affects the Indian entity’s reported profits and can also influence withholding tax, permanent establishment analysis and the group’s Pillar Two calculations.

For example, a royalty arrangement recommended during a restructuring must be supported by the transfer pricing analysis, contractual terms and evidence of the benefits received. If these documents contradict each other, the group may face questions from tax authorities.

What Evidence Should You Request?

• An example of how the tax firm you are considering coordinated transfer pricing with treaty or structuring advice.
• A clear explanation of who checks consistency across agreements, tax calculations and supporting documentation.
• Details of how the firm works with your existing transfer pricing provider, if the work is handled separately.
• Confirmation that it can manage documentation requirements for both current and earlier tax years.

The key is accountability. Establish who reviews the combined position before a transaction is implemented and who resolves disagreements between advisers. 

Consistent advice across workstreams reduces the risk of conflicting positions during an assessment.

Checklist Item 6: Dispute Resolution Across Jurisdictions

A transfer pricing adjustment in India can create double taxation if the other country taxes the same income without granting corresponding relief. 

Your international tax adviser should understand both India’s domestic appeal process and the treaty mechanisms available to resolve the dispute.

The Mutual Agreement Procedure (MAP) allows the competent authorities of two countries to discuss how to resolve a tax dispute under their treaty. A bilateral Advance Pricing Agreement (APA) can provide greater certainty over the pricing of covered transactions for agreed future years.

What Evidence Should You Request?

• Examples of MAP or bilateral APA work involving your parent company’s jurisdiction.
• Details of how the firm coordinates with foreign advisers and competent authorities.
• A plan for managing domestic appeals while treaty negotiations continue.
• Clarity on fees and responsibilities if the dispute lasts several years.

A pending MAP does not automatically extend Indian assessment or appeal deadlines. For instance, objections to a draft assessment order generally must be filed with the Dispute Resolution Panel within 30 days of receiving the order.

Choose an international tax advisory firm that can coordinate both routes, protect domestic procedural rights and explain how it would pursue relief from double taxation.

Checklist Item 7: Sector Specialisation

International tax issues vary by industry. Technology groups may face questions about software payments, royalties and permanent establishment risks from employees working across borders. 

Pharmaceutical companies need advice on intellectual property, research costs and royalty arrangements. Manufacturers may need support with cross-border component purchases, contract manufacturing margins and customs valuation.

A firm’s sector experience should extend beyond knowing the terminology. Its advisers should understand the transactions common to your industry and how Indian tax rules interact with the group’s international arrangements.

What Evidence Should You Request?

• Examples of recent international tax engagements in your sector.
• Details of the specific issues handled and the approach taken.
• Anonymised case studies showing how the firm addressed the tax exposure.
• The names and experience of the people who would work on your account.

If your group operates across several industries, prioritise the sectors with the largest cross-border transactions or tax exposure. 

A firm with relevant experience in your most significant business area may be a better fit than one offering broad industry coverage without comparable depth.

Look for evidence of work completed, not simply your industry’s name on a list of focus areas.

Choosing The Engagement Model 

Before comparing fees, decide how the Indian tax adviser will work with your group’s existing global firm. Here are three models you should consider: 

1. Consolidated Model: One firm handles the India mandate and global coordination. This gives you a single point of accountability, provided the firm has both international tax expertise and the ability to handle Indian assessments and disputes.

2. Split Model: The global adviser manages group tax policy, while an India specialist handles local advisory, documentation and disputes. This provides access to specialised expertise, but requires clear coordination to prevent conflicting positions.

3. Hybrid Model: The India firm handles local tax advice and disputes, while the global adviser retains responsibility for group-wide work such as Pillar Two modelling. Both teams agree on how Indian data, treaty positions and MAP cases will be coordinated.

The right model depends on your group’s needs, existing relationships and the complexity of its Indian operations.

What to Agree Before Signing

Whichever model you choose, establish the following in writing:

• Accountability: A named lead partner and clear responsibilities for each adviser.
• Coordination: How advice will be reviewed and disagreements resolved.
• Scope: The services included and excluded from the engagement.
• Fees: Pricing for routine advice, projects and dispute proceedings.
• Updates: How the firm will flag legal changes that affect your structure.

A global network may offer broader international coordination, while an India-focused firm may provide closer access to local specialists. Neither is automatically the better choice. Ask both to demonstrate how they would handle your actual requirements.

Where PKC Management Consulting Fits

When your group weighs a consolidated, split or hybrid model, we fit where India depth matters most.

PKC Management Consulting is a Chennai-based chartered accountancy and management consulting firm built for the India-focused specialist role: transfer pricing advisory, documentation and compliance handled by advisers who work Indian assessments and disputes every day, while your global firm retains group-wide responsibilities such as Pillar Two modelling and MAP coordination. 

PKC can be the local specialist you can hold to account with clear scope, named responsibility and direct access to the people doing the work. 

Ask us for relevant experience and supporting evidence, and apply the same test to every firm on your shortlist.

Compare PKC’s International Tax Capabilities

FAQs

What does an international tax advisory firm do for a multinational in India? 

It advises on how Indian tax law and your home country’s rules apply to the same transactions: treaty benefits, withholding, permanent establishment risk, structuring, transfer pricing coordination, the global minimum tax, and disputes that cross borders. The value lies in connecting these areas into one view.

Do Indian subsidiaries of multinational groups need to worry about pillar two? 

Yes, if the group has consolidated revenue of at least €750 million. Low-taxed Indian profits, for example from SEZ benefits or tax holidays, can attract top-up tax collected abroad unless a safe harbour such as the side-by-side election applies to the group.

How does the India-Mauritius treaty change affect investors? 

The protocol adds a principal purpose test in Article 27B, which can deny treaty benefits where obtaining the benefit was one of the principal purposes of an arrangement. It entered into force on 10 August 2026 and applies prospectively. Shares acquired before 1 April 2017 remain outside the test.

What is the difference between a retainer and a project engagement for international tax advice? 

A retainer provides ongoing access for recurring questions. A project covers a defined task with a start and an end, such as a structuring review. A hybrid combines a small retainer with fixed-fee projects, and it often suits groups whose India questions arrive in bursts.

How do you check whether an advisory firm can coordinate across jurisdictions? 

Request three things from the firm: a named contact in your parent company’s country, a redacted example of a cross-border case involving two countries, and a written procedure for coordinating with other advisers.