✔️ How are Foreign Enterprises taxed?
✔️ Key Modes of Setting Up a Presence in India
• Liaison Office
• Branch Office
• Project Office
• A Joint Venture
• A Subsidiary
✔️ Key Tax Risks Associated with Each Mode
• Permanent Establishment (PE) Risk
◦ What is a PE?
◦ Factors that can give rise to a PE
◦ Managing PE exposure
• Residence Risk – Having a Place of Effective Management in India
• AOP Risk in Case of Unincorporated Joint Ventures
◦ Attributes of an AOP
• POEM Risk – Tax residence of Foreign Company in India
✔️ Jurisdictional Analysis for Tax-Efficient Cash Repatriation
✔️ Anti-Abuse Provisions – Transfer Pricing, Thin Capitalisation & GAAR
