Notes & insights.
Periodic notes from the partnership on cross-border tax, FEMA changes, the Indian regulatory environment, and what we learn working alongside founders, investors, and family offices.
Recent notes
The Income-tax Act, 2025: what actually changes for founders, NRIs and foreign companies.
India replaces the 1961 Act from 1 April 2026. Mostly a renumbering and a new “tax year” — but every section reference in your ESOPs, valuations and TP files needs a second look. A plain-English guide with a 1961 → 2025 section map.
Read the full noteForm 13 LDC for NRIs: when it works, when it doesn't.
A practical note for NRIs selling Indian property. Section 195 imposes 20.8% TDS on the full sale consideration; Form 13 reduces that to the actual capital gains rate. We walk through when the application succeeds, when it fails, what to file, and what to do when timing is against you.
Read the full noteFlip structuring after GAAR. Delaware, Singapore, Cayman, IFSC, UAE compared.
Indian startups going offshore now operate in a post-GAAR, post-PoEM, post-Section 9 reality. We compare five common destination jurisdictions across substance requirements, capital-gains exposure, ESOP migration, IP transfer, and cost. There is no single right answer, but there are wrong ones.
Read the full noteWhat changed in India-US transfer pricing for FY26.
Three meaningful changes (Master File / CbCR threshold revision, the Safe Harbour rules update for IT/ITeS captives, and the Advance Pricing Agreement programme's data-driven turnaround acceleration) meaningfully shift how Indian arms of US groups should approach FY26 documentation.
Read the full noteMailing list
To be notified when we publish, email [email protected] with "Insights mailing list" in the subject. We send updates only when we publish, typically once a quarter, sometimes more if a regulatory change demands it.
For journalists & researchers
For interview requests, citation-ready summaries of our positions on cross-border tax, or speaking engagements at industry events, contact [email protected].
Guides & tools
NRI selling property in India: TDS, Form 13 & repatriation
Cut 20.8% Section 195 TDS to your actual capital-gains rate, with a worked example and the repatriation path.
Read the guideNRI property TDS & Form 13 savings estimator
Estimate the TDS withheld, the tax actually due, and the cash a Form 13 certificate could free up.
Open the calculatorIndia entry for foreign companies: subsidiary, FEMA & GST
Choosing the vehicle, incorporation, FDI/FC-GPR, GST and transfer pricing — a practical setup guide.
Read the guideIndia–US cross-border tax: DTAA, withholding, PFIC & GILTI
Treaty positions, Section 195 with 15CA/15CB, US-person exposure and transfer pricing in one place.
Read the guide