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Corporate Tax 2011
A practical cross-border insight to corporate tax work
Published by Global Legal Group with contributions from:
Aivar Pilv Law Office Arias & Muñoz Avanzia Taxand Limited Avbreht, Zajc & Partners, Ltd. BC Toms & Co Boga & Associates Borden Ladner Gervais LLP Bredin Prat Bustamante & Bustamante Candal-Taxand Cárdenas & Cárdenas Abogados Ltda. CMS Cameron McKenna LLP Cuatrecasas, Gonçalves Pereira Dorda Brugger Jordis Dr Dr Batliner & Dr Gasser Elvinger, Hoss & Prussen Eubelius Gide Loyrette Nouel Greenwoods & Freehills Hannes Snellman Attorneys Ltd. Hendersen Taxand Herzog Fox & Neeman HNP Counsellors Limited – Taxand Thailand Juridicon Law Firm Kilpatrick Stockton LAWIN Lee and Li, Attorneys-at-Law Lenz & Staehelin LOGOS legal services McCann FitzGerald Nagashima Ohno & Tsunematsu Negri & Teijeiro Abogados P+P Pöllath + Partners Pachiu & Associates Pedersoli e Associati PRA Law Offices Proskauer Rose LLP Salans Simpson Grierson Slaughter and May TEMPLARS White & Case Yoon & Yang LLC
In the case of the transaction of sale of goods occurring in one State and such transaction does not involve movement of goods in the course of inter-state. 1956.5 Are treaties overridden by any rules of domestic law (whether existing when the treaty takes effect or introduced subsequently)? In India. This is levied under the Central Sales Act. as the case may be. the provisions of DTAA over ride the domestic laws. 1. in relation to the assessee to whom such agreement applies. In India.UK 113 . or as the case may be. 1961 empowers the Central Government to enter into double tax avoidance agreements with other countries. then. 1961. thereby ensuring the process tax neutrality in transactions between residents and non-residents. shall not be regarded as less favourable charge or levy of tax in respect of such foreign company.e. 1. Stamp duty is payable at the rates specified in the Indian Stamp Act. The object of such agreements is to evolve an equitable basis for the allocation of the right to tax different types of incomes between the ‘source’ and ‘residence’ status.Chapter 22 India PRA Law Offices Premnath Rai P. Some of the States have introduced Value Added Tax laws in replacement of the State Sales laws.3 Do treaties have to be incorporated into domestic law before they take effect? In India. stamp duty is levied on a number of instruments. the provisions of the Income Tax Act. Since introduction of such a uniform valued tax laws regime require consent of the State Government. 1899. 1961. the Explanation to Section 90(3) specifically provides that charge of income-tax in respect of a foreign company at a rate higher than the rate at which a domestic company is chargeable.ICLG. Srinivasan 1 General: Treaties 1. 2.. London WWW. under section 90(1) for granting relief of tax. Such date could precede or follow the date of the agreement. However. However. 1956. 1. Please see Annexure–A which lists the countries with which India has double tax avoidance agreements. the domestic law shall apply with respect to such assessee. the Central Government issues a notification under the Income-tax Act.1 How many income tax treaties are currently in force in India? India has entered into Double Tax Avoidance Agreements (DTAA) with 60 countries under Section 90 of the Income Tax Act. 1. Thus insofar as the domestic laws are more favourable to the assessee than the DTAA.CO.4 Do they generally incorporate anti-treaty shopping rules (or “limitation of benefits” articles)? India has many DTAAs in which anti -treaty shopping rules have been incorporated such as India’s DTAA with Singapore and UAE. shall apply to the extent they are more beneficial to that assessee.2 Do you have Value Added Tax (or a similar tax)? If so. India also has a number of DTAAs with other countries which do not have anti-treaty shopping provisions. avoidance of double taxation. at what rate or rates? Section 90 of the Income-tax Act. (i. sales tax is payable at the rate specified in the respective State Sales Tax law. the Central Government is in discussion with the State Governments to arrive at consensus in introducing uniform value added tax laws.2 Do they generally follow the OECD or another model? outside India. sales tax is payable at the rate specified in the Central Sales Tax Act. 1961. and the respective State Sales Tax laws. In the case of goods moving from one State to another in the course of inter-state trade. sales tax is payable on sale of goods. However. under Section 90(2) of the Income Tax Act. The Central Government has evolved a road map for introducing a uniform value added tax laws regime throughout the country. which introduces a multi-stage tax on goods that is levied across various stages of production and supply with credit given for tax paid at each stage of value addition. the Central Government legislation) and the respective State stamp legislation. 1961. specifying the date on which the agreement enters into force.1 Are there any documentary taxes in India? India follows a near uniform pattern in as much as India has guided itself by the UN model of double tax avoidance agreements. 2 Transaction Taxes 2. Following the signing of the double taxation avoidance agreement. if the Central Government has entered into an agreement with the Government of any country outside India or specified territory ICLG TO: CORPORATE TAX 2011 © Published and reproduced with kind permission by Global Legal Group Ltd.
and stamp duty on instruments. but before 1st April. royalty is considered as accruing in India and. 3. Rates of taxation: In the absence of a double tax avoidance agreement in respect of agreement made up to 31st March 1976. a domestic company is required to pay a tax on distributed profits (the dividend distribution tax) at the rate of fifteen percent. royalty is taxable in the hands of non-residents if the same are received in or accrued in India. 1976. Royalty and fees for technical services received in pursuance of agreement made after 31st March. Hence. it is the place of use of the intellectual property that governs the place of accrual. assembly. In the case of non-resident non-corporate persons. what are the relevant restrictions? Input tax credit can be availed by a person. It makes no difference whether the consideration is by way of lump sum payment or in the form of recurring payments based on production or any other factor.UK ICLG TO: CORPORATE TAX 2011 © Published and reproduced with kind permission by Global Legal Group Ltd. immovable properties are excluded from levy of VAT. if the income is payable by the Government.. Fees for technical services refer to any consideration for the Yes. in the absence of a double tax avoidance agreement. commercial or scientific knowledge or skill. If the services are utilised in business or profession in India or for purpose of earning income from any sources in India. Royalty has been defined to mean consideration for transfer of rights in respect of or for use of intellectual property viz. service tax on provision of services. does not apply in relation to lump sum royalty payment made by a resident for transfer of right in respect of computer software which is supplied by a non-resident manufacturer along with the supply of computer or computer-based equipment under any scheme approved under the policy on Computer Software Export. however. whether such consideration is paid in a lump sum or in any other manner. tax withholding is applicable on payment of royalty to the nonresident recipient. etc. anti-dumping and safe guard duties to prevent dumping.CO. accordingly chargeable to tax. London . Further. Such lump sum payment is treated as business income of the manufacturer. if the nonresident shareholder receives any dividend. became taxable on Gross receipt basis without deduction of any expenses at the flat rate of thirty percent. who is registered under the VAT laws). However.6 Are there any other indirect taxes of which we should be aware? A number of other indirect taxes are payable in India such as customs duty on imports of goods and services. a flat rate of twenty percent on Gross receipts is applied without there being any requirement of approval or without any requirement of the agreement being in accordance with the industrial policy.2 Would there be any withholding tax on royalties paid by a local company to a non-resident? Yes. The agreement with Indian concern is required to be approved by the Central government but if it relates to a matter included in the industrial policy of the Government of India and the agreement is in accordance with that policy. Once the dividend distribution tax is paid. The above position. 1997. patent. Such income of foreign companies received in pursuance of agreement after 31st March. It. incomes from royalty and fees for technical services was computed on actual basis after deduction of expenses which could not have exceeded twenty percent of the gross receipt.5 Are there any other transaction taxes? India levies a host of indirect taxes such as Service Tax. process or trade mark and similar property. however. model. does not include an income which arises from the transfer of the asset itself and is liable to be taxed in the hands of the recipient as ‘Capital Gain’. it is the place where the services are utilised that determine the accrual of income in India. Gift Tax. no withholding tax is imposed on dividends paid by a domestic company to its shareholders. 3. Software Development and Training 1986 of the Government of India. In respect of payment made by others.e. In case of royalty in consideration of the transfer of rights in respect of Computer Software permitted to be imported under Open General Licence. 1997. excise duty on manufacture of goods. It also includes consideration for providing services of technical or other personnel as part of their service contract. industrial. Income of this nature is considered as always accruing in India if the same is payable by the Government.3 Would there be any withholding tax on interest paid by a local company to a non-resident? The VAT laws of various states in India provide exemption to various classes of goods and transactions. however.ICLG.3 Is VAT (or any similar tax) charged on all transactions or are there any relevant exclusions? India rendering of any managerial. 2. If the right property or information for which royalty is payable is used for the purposes of business or profession in India or for earning income from any source in India.1 Is any withholding tax imposed on dividends paid by a locally resident company to a non-resident? Per Section 115-0 of the Income-tax Act.e.PRA Law Offices 2. this income is taxed at the normal rate prescribed in the Finance Act on net income basis i. who is a registered dealer (i. Similarly ‘Fees for technical services’ is taxable in the hand of nonresidents if the same is received in India or it accrues in India. such approval is not necessary. does not include consideration for any construction. Securities Transaction Tax. is taxable at twenty percent of gross receipts. secret formula. where the total income of a non-resident includes any income by way of 114 WWW. property tax on immovable properties. 3 Cross-border Payments 3. income-tax is payable at the rate of twenty percent. It is considered as always accruing in India. It. 1961. invention. mining or like projects undertaken by the recipient or consideration which would be income of the recipient chargeable under the head ‘salary’ by virtue of the existence of an employeremployee relationship between the parties. dividend distribution tax. 2. including its non-resident shareholders. technical or consultancy services. It includes consideration for imparting of information concerning the working or use of those properties and also for imparting of information concerning technical.4 Is it always fully recoverable by all businesses? If not. design. the dividend income is tax free in the hands of the shareholder. Input tax credit can be availed in accordance with the CENVAT credit rules. the fees accrues in India regardless of any other factor existing. In India. after deduction of incidental expenses. If the income is payable by any other person. which has not suffered the dividend distribution tax. India 2.
For example.ICLG. the tax follows the commercial accounts subject to certain adjustments. London WWW.7 Are there any restrictions on tax relief for interest payments by a local company to a non-resident in addition to any thin capitalisation rules mentioned in questions 3. other tax base)? Since India does not have a regime of thin capitalisation rules.4 If it otherwise differs from the profit shown in commercial accounts. 1961. if any. if any. India has introduced a process called “advance ruling” whereby (i) a non-resident can seek determination of tax liability of the nonresident on a transaction which has been undertaken or proposed to be undertaken by a non-resident or (ii) a resident can seek determination of tax liability of a non-resident arising out of a transaction which has been undertaken or proposed to be undertaken by a resident applicant with a non-resident (see Chapter XIX-B of the Income-tax Act. effective rate of three percent). 3. as reduced by the amount. in addition to headline rat of tax. 4.CO. Effective corporate income-tax rate applicable for the India does not permit group companies to be taxed on the basis of consolidated accounts.1 What is the headline rate of tax on corporate profits? The rate of income tax payable by a domestic company for the assessment year 2010-11 is thirty percent.33% (secondary and higher education cess) = 33. 1961. Advance tax is payable on the current income calculated in the manner laid down in section 209 of the Income Tax Act. However. what are the main other differences? No. 4. 1961. paid in the earlier instalment or instalments. mandates that for computing profits for income-tax purposes.99% .9% India does not have a regime of thin capitalisation rules. If the accounting standards stipulate standards for accounting purposes different from the rules specified in the Income-tax Act. However.UK 115 India On income exceeding ten million rupees: 30% + 3% (surcharge) +0.6% ( education cess) +0. 1961.4-3.66% (education cess) +0. profits? A corporate entity is required to pay income-tax on its net profits. 3.82% (education cess) + 0.6 Would any such “thin capitalisation” rules extend to debt advanced by a third party but guaranteed by a parent company? In India..3% (secondary and higher education cess) = 30.e. as opposed to retained. Further education cess of two percent is payable on income tax and surcharge and secondary and higher education cess of one percent is payable on the amount of income tax and surcharge. 1961). India proposes to introduce “safe harbour” rules on Transfer Pricing and the proposal is at an advanced stage of consideration. paid in the earlier instalment or instalments. the depreciation should be calculated on written down value method. if any.6 Is tax imposed at a different rate upon distributed. there are no rules providing for tax on third party debt guaranteed by a parent company.3 What is the tax base for that tax (profits pursuant to commercial accounts subject to adjustments. Further.5 Are there any tax grouping rules? Do these allow for relief in India for losses of overseas subsidiaries? 4 Tax on Business Operations: General 4.6 above? In general terms. depreciation may be computed on straight line method for accounting purposes. On or before the 15th December – Not less than seventy-five percent of such advance tax. On or before the 15th September – Not less than forty-five percent of such advance tax. 3. An additional tax called tax on distributed profits is payable by the ICLG TO: CORPORATE TAX 2011 © Published and reproduced with kind permission by Global Legal Group Ltd. CBDT has set up a committee to formulate Safe Harbour provisions which would enable the Income Tax Authorities to accept without scrutiny tax returns of Indian units of Foreign Companies.2 When is that tax generally payable? India does not have a “safe harbour” regime at present to provide tax relief. the Income-tax Act. at ten percent on the headline rate of tax (i. 4.4 Would relief for interest so paid be restricted by reference to “thin capitalisation” rules? India Assessment Year 2010-11 is as follows: Domestic company: On income not exceeding ten million rupees: 30% + 0% (surcharge) +0. all companies who are liable to pay income tax are required to pay advance tax as per the following schedule: On or before the 15th June – Not less than fifteen percent of such advance tax. there are no such restrictions.PRA Law Offices interest received from the Government or an Indian concern on monies borrowed or debt incurred by Government or the Indian concern in foreign currency. 4. On or before the 15th March – The whole amount of such advance tax as reduced by the amount or amounts. 3.41% (secondary and higher education cess) = 42. as reduced by the amount or amounts. 1961.23% 4.5 If so. paid in the earlier instalment. surcharge is payable.8 Does India have transfer pricing rules? India does have transfer pricing rules as specified in section 92 to section 92F of the Income Tax Act. in case of domestic companies having a net income in excess of ten million rupees. is there a “safe harbour” by reference to which tax relief is assured? Foreign Company: Base tax rate 40% + 1% (surcharge) + 0. without any distinction whether net profits is retained or distributed. profits for income-tax purposes should be computed in accordance with the provision of the Income-tax Act. income tax is payable in India at the rate of twenty percent. 3.
on formation. 5 Capital Gains 5.8 Are there any local taxes not dealt with in answers to other questions? Short term capital gains 15. Capital assets are of two types i. effective tax tion cess @ 1%. MAT was introduced in the direct tax system to ensure that companies having large profits and declaring substantial dividends to shareholders but who were not contributing to the Govt by way of corporate tax. 4. a tax called Minimum Alternate Tax (MAT) is payable on the book profits of the company. etc. In a number of DTAAs. it repatriates to its parent company.secondary and higher education cess @1%. 5. Dividend distribution tax is not payable by a branch office of a foreign company. the country of residence of the shareholder has this right and in some others the country of residence of the transferor has the right if the shareholding of the transferor is of a prescribed percentage. Longterm capital assets are assets held for more than 36 months before A branch of a foreign company will be subject to taxation in India at 42.83625% 20.5% education cess @2% + sec+ education cess @2% + ondary and higher education secondary and higher educacess @1%. The rate of capital gains tax is also different for residents and nonresidents. 6. agricultural land (other than within municipal areas or within 8 kilometers from it wherever notified) and gold bonds. Once tax on distributed profits is paid. by availing the various incentives and exemptions provided in the Income-tax Act.e. effective rate = 22.5% education cess @2% + + education cess @2% + secondary and higher educa. 5. a shareholder will be able to claim exemption from capital gains tax arising from sale of shares held in Indian company. London . capital duty) would be imposed upon the formation of a subsidiary? A subsidiary of a foreign company incorporated in India would be an Indian company and will be subject to tax and exemptions as applicable to any other domestic company in India. short term capital gains and long term capital gains.995% rate = 15. The tax rates applicable on capital gains are as follows: Domestic companies Foreign companies India Apart from the taxes discussed above.g. personal effects.7 What other national taxes (excluding those dealt with in “Transaction Taxes”.g. Jewellery and ornament are not personal effects and hence their sale will attract capital gains tax.0% + surcharge* @2.0% +surcharge* @2. the right to tax is given to the State in which the company is resident. A domestic company is required to pay dividend distribution tax at 15% on the amount it distributes by way of dividend. namely short term capital gains and long term capital gains (see question 5. effective rate tion cess @1%. the tax paid in India could be set off against the total tax payable by the parent company abroad. There are separate rules for computing capital gains which provide for inflation–linked adjustment in determining the cost of the capital asset. effective tax =16. Capital asset means all moveable or immovable property except trading goods.2 for details). Different provisions exist for taxation of capital gains arising from transfer of shares. 1961.66% tax rate = 21. the dividend income becomes tax-free in the hands of the shareholder.ICLG.23% on income accrued in India.3 Is there a participation exemption? There are no other local taxes.0% + surcharge* @10% + 15. property taxes.2 If so. 116 WWW.CO.115% Long term capital gains * Surcharge is applicable if the net income exceeds ten million rupees.0% + surcharge* @10% + 20. long term and short term.e.UK ICLG TO: CORPORATE TAX 2011 © Published and reproduced with kind permission by Global Legal Group Ltd.PRA Law Offices company at he rate of fifteen percent on the amount distributed by way of dividend. a subsidiary of a foreign company would not be required to pay any special taxes or capital duty.. exemption from capital gains taxes are available when the gains from sale of capital assets are reinvested in some other capital assets in terms of section 54B to section 54 GA Income Tax Act. Different rates of tax apply for gains on transfer of the long term and short-term capital assets. In some other cases.1 What taxes (e.1 Is there a special set of rules for taxing capital gains and losses? Depending n the provisions in the DTAA. on the amount of net profit after tax. Apart from the company incorporation related fees and stamp duties (which are payable irrespective whether the company is a domestic company or a subsidiary of a foreign company). is the rate of tax imposed upon capital gains different from the rate imposed upon business profits? Yes. 6 Branch or Subsidiary? 6. In case of shares.e. But if there is a double taxation agreement with the country in which the foreign company is incorporated. 1961. Gains on short-term capital asset are taxed as regular income. which is higher than the corporate tax payable by domestic company. the profits arising out of such sale are taxable as capital gains in the year in which the transfer takes place. pay a fixed percentage of book profit as minimum alternate tax. 5. debentures and mutual fund units the period of holding required is only 12 months.4 Is there any special relief for reinvestment? If any ‘capital asset’ is sold or transferred.. Gains arising from transfer of immovable properties are taxed in the country where such properties are situated.2 Are there any other significant taxes or fees that would be incurred by a locally formed subsidiary but not by a branch of a non-resident company? The capital gains tax rate differs according the category of capital gains i. Gains arising from the transfer of movable assets forming part of the business property of a permanent establishment are taxed in the country where the permanent establishment is located. 4.? India they are sold or transferred. above) are there . Capital gains are classified into two categories. MAT is currently levied at the rate of ten percent.
and on establishing that it ICLG TO: CORPORATE TAX 2011 © Published and reproduced with kind permission by Global Legal Group Ltd. the effective tax rate in the case of a foreign company.5 Would a branch benefit from tax treaty provisions. No withholding tax would be applicable on remittance of profits on which the applicable corporate income-tax has been paid. the same can be disregarded or re-characterised by the Commissioner of Income-Tax (CIT). Yes. or some of them? The Draft Direct Taxes Code which is set to replace the existing Income Tax Act. 1961. or a part or whole of. an arrangement. London WWW. foreign companies will be required to pay branch profit tax. to its parent company. Further. as per CBDT Circular: No. The term impermissible avoidance arrangement has been defined to mean a step in. as per the proposed Direct Tax Code though uniform tax at the rate of thirty percent is proposed to be imposed on both domestic and foreign companies.3 How would the taxable profits of a local branch be determined? India has earned the net profit by undertaking the permitted activities. 6. a branch of a foreign company is not liable to pay branch profit tax. the tax to be deducted is at the rate provided in the Finance Act of the relevant year or at the rate provided in the DTAA. after payment of the applicable corporate income-tax thereon. 6. Subject to any treaty provisions to the contrary.1 How does India address the issue of preventing tax avoidance? For example. 6.UK 117 India . Though the intention of the Government to enact GAAR provisions seems to prevent treaty abuse by non-residents. the taxable profits of a local branch of a foreign company would comprise: Trading income arising directly or indirectly through or from the branch office or reasonably attributable to the permitted business operations of the branch office in India. 728. or it is not entered into for bona fide purposes.PRA Law Offices 6. whereas.CO. is there a general antiavoidance rule or a disclosure rule imposing a requirement to disclose avoidance schemes in advance of the company’s tax return being submitted? At present. The Direct Tax Code proposes to introduce GAAR in its widest amplitude and discretionary powers have been vested with the Commissioner to apply GAAR. after reckoning the branch profits tax will be 40. in terms of Section 9(1) of Income Tax Act. which is an impermissible avoidance arrangement. whose main purpose is to obtain a tax benefit. whichever is more beneficial to the assessee.5%.13%. The effective rate of tax for a domestic company after considering the dividend distribution tax will be 39.4 Would such a branch be subject to a branch profits tax (or other tax limited to branches of non-resident companies)? 7 Anti-avoidance 7. on production of the prescribed documents. its applicability to domestic arrangements is well covered within the provisions. introduces for the first time in the Indian tax laws a provision relating to GAAR (General Anti-Avoidance Rules). 1961. it is presumed that the assessee has entered into an arrangement for obtaining tax benefit and the complete burden lies on the assessee to prove otherwise. The Code provides that if an assessee has entered into any arrangement.6 Would any withholding tax or other tax be imposed as the result of a remittance of profits by the branch? A Branch Office may repatriate its profits. However. and it lacks commercial substance. The Branch Office need not retain any profits as reserves in India.ICLG. dated 30-10-1995 in the case of remittance to a country with which India has a Double Taxation Avoidance Agreement in force.
CO.ICLG.A.R U.A Uzbekistan Zambia 1996-97 2001-02 1995-96 1985-86 1981-82 1996-97 1983-84 2001-02 1996-96 1970-71 1992-93 1994-95 1979-80 118 WWW.PRA Law Offices ANNEXURE-A India Country Australia Commencement – Assessment Year 1993-94 1993-94 1994-95 1997-98 1996-97 1999-2000 (revised) 1986-87 2001-02 (revised) 1985-86 2000-01 (amended protocol) 1958-59 1984-85 1985-86 199-99 1989-90 1995-96 1991-92 1999-00 1983-84 1973-74 1995-96 1990-91 1988-89 1999-00 (amendment) 2001-02 (supplemental protocol) 1999-00 1991-92 1989-90 1999-00 1998 1990-91 1999-00 (revised) 1983-84 1988-89 1999-00 1995-96 1995-95 (revised) 2000-01 1997-98 Country Austria Belgium Belarus Canada Cyprus Denmark France Commencement – Assessment Year 1963-64 1989-90 1999-2000 (revised) 1999-2000 1987-88 1994-95 1991-92 1996-97 (revised) India Bangladesh Brazil Bulgaria China Czechoslovakia Finland F.UK ICLG TO: CORPORATE TAX 2011 © Published and reproduced with kind permission by Global Legal Group Ltd. (Protocol) G.S. London .R.A. G (original) F.R.E U. R.D.G.G (revised) Hungary Israel Japan (revised) Kazakhstan Libya Malaysia Mongolia Nepal Greece 1964-65 Indonesia Italy (revised) Jordan Kenya Malta Mauritius Namibia Netherlands 1989-90 1997-98 2001-02 1985-86 1997-98 1983-84 2000-01 1990-91 New Zealand Norway 1988-89 Oman Poland Romania South Africa Spain Sweden Syria Thailand Turkmenistan U.R F.K Russian Federation Vietnam Philippines Qatar Singapore South Korea Sri Lanka Switzerland Tanzania Trinidad &Tobago Turkey U.
In Practice Verticals. capital raising.in ICLG TO: CORPORATE TAX 2011 © Published and reproduced with kind permission by Global Legal Group Ltd. India. PRA Law has a good blend of Indian and international clients. competition and anti-trust. Ground Floor Greater Kailash – II New Delhi – 110 048 India P. Srinivasan is a Partner of PRA Law Offices (PRA Law). professional qualification and experience of members of PRA Law team. financial services. With its offices in New Delhi and Bangalore. biotechnology & healthcare and not-for-profit organisations. food and confectionery. combinations. PRA LAW OFFICES (PRA Law) is a corporate and commercial law firm that focuses its practice in providing quality and solution oriented services.PRA Law Offices India Premnath Rai PRA Law Offices W-126. mergers and acquisitions.in Tel: +91 11 4067 6703 Fax: +91 11 4067 6768 Email: srini@pralaw. commercial and not-for-profit organisations. insurance & financial services. he worked in the financial services sector in a leading non-banking financial services company and as a senior associate with another Delhi based law firm. takeovers. He advises industry specific clients in sectors such as information technology. he is qualified in the areas of cost accounting. PRA Law has strong presence in the areas of in-bound and out-bound Investments. New Delhi – 110 048 Tel: (91-11) 40 67 67 67 Fax: (91-11) 40 67 67 68 Email: prem@pralaw. apart from general corporate and legal issues. Before joining the firm. legal due diligence. company secretarial and finance. which focuses its practice in the areas of corporate. joint ventures and strategic alliances. PRA Law has strong presence in life and general insurance. PRA Law constantly endeavours to provide solution oriented legal services.UK 119 India . in addition to advising clients in other sectors and projects. biotech and pharmaceutical. He has advised Indian and foreign clients on a variety of transactions involving mergers. He focuses his practice in areas of corporate restructuring. Vyalikaval. Delhi Office W-126. 2nd Main. 4113 7814 Fax: (91-80) 2334 2415 email: satish@pralaw. competition and domestic & international trade laws including anti-dumping investigations. a New Delhi based law firm that focuses on corporate and commercial laws. Greater Kailash – II. Bangalore-560 003 India Tel: (91-80) 2334 2414.ICLG. In addition to being a lawyer.in Bangalore Office 54/1.in Premnath Rai is a founder member of PRA Law Offices (formerly known as Premnath Rai Associates). legal and regulatory audit. healthcare and hospitality. Prior to moving to taking up private practice. corporate restructuring. PRA Law serves a wide range of client needs in Practice Horizontals and Practice Verticals. employment laws. acquisitions. Srinivasan PRA Law Offices W-126. He is one of the initial members in PRA Law. He has presented papers in national and international programmes and conferences and contributed articles to leading international publications. Ground Floor. international tax and capital markets. Ground Floor Greater Kailash – II New Delhi – 110 048 India Tel: +91 11 4067 6701 Fax: +91 11 4067 6768 Email: prem@pralaw. he served as general counsel of Indian subsidiary of a leading international IT major. securities law. commercial and business laws. PRA Law renders pro-bono services. He has contributed articles on mergers & acquisitions. apart from traditional manufacturing and services companies. Members of PRA Law team devote a part of their time and efforts to specific focused areas of practice and actively participate in professional. As part of discharging its professional and societal responsibility. Law (University of Bangalore) and a Fellow Member of the Institute of Company Secretaries of India. P. In Practice Horizontals. information technology (IT) and IT Enabled Services. With the diverse knowledge. joint ventures and collaborations. PRA Law is well positioned to serve its clientele and cater to their needs.CO. competition law and has attended conferences and seminars on corporate restructuring. industry and academic activities. He is a graduate in Commerce (University of Mysore). corporate and business structuring & restructuring. PRA Law focuses its practice in its specialised domain of corporate and commercial laws including dispute resolution and litigation. and a network of professional associates in other major cities in India and abroad. corporate and tax litigation and arbitration. London WWW.
co.uk www.ICLG.The International Comparative Legal Guide to: Corporate Tax 2011 Other titles in the ICLG series include: Business Crime Cartels & Leniency Class Actions Commodities and Trade Law Competition Litigation Corporate Governance Corporate Recovery & Insolvency Dominance Employment Law Enforcement of Competition Law Environment Law Gas Regulation International Arbitration Litigation & Dispute Resolution Merger Control Mergers & Acquisitions Patents PFI / PPP Projects Pharmaceutical Advertising Product Liability Public Procurement Real Estate Securitisation Telecommunication Laws and Regulations To order a copy of a publication.uk . please contact: Global Legal Group 59 Tanner Street London SE1 3PL United Kingdom Tel: +44 20 7367 0720 Fax: +44 20 7407 5255 Email: firstname.lastname@example.org.