Banking and Financial Services Tax (BFSI)

��㣨Leyu�� in India’s Banking, Financial Services and Insurance (BFSI) team caters to clients in the BFSI space such as banks, non-banking finance companies (NBFCs), insurance/reinsurance companies, foreign portfolio investors, stock-brokers, mutual funds, asset management companies, etc. The team consist of professionals from wide variety of backgrounds with deep knowledge and experience.

We provide a wide range of services including tax and regulatory compliance, regulatory approval assistance, advisory and litigation support. BFSI Tax Team has also been leading advocacy initiatives before the India’s apex tax administering authority i.e. Central Board of Direct Taxes (CBDT).

The ��㣨Leyu�� differentiator

Our BFSI practice is focused on finding opportunities and leveraging them to the advantage of clients through tailored and progressive approaches. The practice has been built upon complementary components of industry/sector knowledge, multifaceted tools and the ability to deliver services locally and globally.

The team has extensive experience in providing a wide range of tax and regulatory services to multinational companies in the financial services sector. We have senior advisors on board who in the past have worked with regulators/revenue department, providing valuable perspective.

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Our BFSI practice is dedicated and a focused tax practice serving major banking and financial services client

We assist our clients in the following areas:

Tax advisory services
Compliance services
Income-tax Assessment/Litigation Support
Regulatory services
Foreign Portfolio Investor services

Conceptualisation and structuring of funds, entities and business arrangements
Cash repatriation planning
Advisory on taxation of dividend, interest, royalty/FTS
Beneficial ownership analysis
Analysis of applicability of General Anti-Avoidance Rule, Place of Effective Management, Permanent Establishment

Analysis of indirect transfer provisions
Multilateral instrument impact analysis including Principal Purpose Test analysis
Equalisation levy/significant economic presence impact analysis
Advisory and implementation of setting up units in Gujarat International Financial Services Centre
Tax due diligence

Assistance in preparing and filing of annual tax returns
Obtaining lower withholding tax certificate
Managed tax services in respect of TDS and other compliances
TDS health check up
Certification and remittance letters
FATCA compliance services
Transfer pricing compliance

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Assistance in preparation and filings of appeals before the Commissioner of Income-tax (Appeals) [CIT(A)], Dispute Resolution Panel (DRP) and Income Tax Appellate Tribunal (ITAT)

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Assistance in preparation of technical submissions to be filed before Assessing Officer (AO), CIT(A), DRP and ITAT and provide support for representation before CIT(A) and DRP to argue the appeals

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Assistance with advance ruling application before the Authority for Advance Rulings (AAR)/Board for Advance Ruling (BAR) for settling a tax position

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Assistance in applications to the competent authority for Mutual Agreement Procedure (MAP) under the tax treaties

Briefing the company’s counsel on the factual position of the company’s matter for the purpose of such counsel’s appearance in appellate proceedings, before the CIT(A), ITAT, AAR, BAR, High Court and Supreme Court.
Advance Pricing Arrangement

Obtaining refunds from tax department
Tax technology tools for compliance and litigation
Advocacy and representation before the CBDT/Ministry of Finance

Advise on matters relating to Company Law, Reserve Bank of India, Securities Exchange Board of India, International Financial Services Centres Authority, Insurance Regulatory Development Authority, Foreign Direct Investment, FATCA regulations, etc.
Assistance in seeking regulatory licence/approvals i.e., banking, insurance, NBFCs, mutual fund registrations, broking, asset reconstruction companies, etc.
Assistance in representation before the regulators
Assistance in complying with regulatory due diligence

We have a dedicated team with vast and varied experience in providing focused services to FPIs. Our team of professionals have an in-depth knowledge of local laws, as well as practical experience with issues relating to FPIs�� investments into India.

Our experience and knowledge about the requirements of the FPI clientele and contemporary knowledge of the latest regulations in a wide array of jurisdictions enables us to assist in designing a tax efficient structure for investments by foreign entities.

We also conduct road shows, along with local custodian bankers, on tax developments in India.

We have good working relationships with all the leading Indian Designated Depository Participants (DDPs) and Custodians providing custody services to FPIs investing in India.

We have been providing services to more than thousand FPIs, and inter alia have been assisting our clients in the following areas:

Jurisdictional analysis for setting up of fund
Assistance in preparation/reviewing FPI applications to be submitted to DDP
Assistance in obtaining Permanent Account Number
Computing capital gains tax liability on the sale transactions executed by the FPI

Computing and assisting in monitoring advance tax payments
Assisting in preparing and filing annual tax returns
Assisting in assessment/litigation support services
Advising on matters relating to tax treaty benefits eligibility (i.e. beneficial ownership, etc.) for various streams of income