Are startups eligible for 80-IAC?

Yes — DPIIT-recognized startups can claim 100% deduction for any 3 consecutive years out of first 10. Inter-Ministerial Board certification required.

When is transfer pricing applicable?

Section 92 — international related-party transactions. Section 92BA — specified domestic transactions exceeding thresholds. Both require maintenance and Form 3CEB filing.

GAAR (Sections 95-102) applies to "impermissible avoidance arrangements" — those lacking commercial substance and primarily for tax benefit. Threshold: tax benefit > ₹3 crore.

Can we restructure tax-neutrally?

Yes — through Section 47 (transactions not regarded as transfer), Section 72A (carry-forward of losses on amalgamation) and similar provisions, subject to conditions.

Tax Planning — Corporate

Corporate tax planning — entity selection, transaction structuring, transfer pricing, cross-border tax, R&D and startup deductions for legal tax minimization.

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Overview

Understanding Tax Planning — Corporate

Corporate Tax Planning is a strategic exercise that integrates tax considerations into business decisions — entity selection (Pvt Ltd vs LLP vs OPC), business structuring (single entity vs holding-subsidiary), transaction-level planning (slump sale vs share sale, mergers, demergers), transfer pricing for related parties, cross-border structuring under DTAAs and use of regime-specific incentives. Corporates can avail Section 115BAA (22% concessional rate), Section 115BAB (15% for new manufacturing), Section 80-IAC (startup deduction), Section 35 R&D deductions, Section 80JJAA additional employment deduction and various other regime-specific benefits subject to conditions. We provide ongoing CFO-level tax advisory for corporates, integrate tax into M&A and financing decisions, structure international operations and represent in tax disputes / appeals.

Why Legal Door

Built for Outcomes, Trusted Pan-India

Specialist lawyers, transparent pricing and end-to-end execution from first call to final order.

CFO-Level Advisory

Tax integrated into business strategy, not just compliance.

M&A Tax Structuring

Slump sale, share purchase, merger, demerger optimized for tax.

Cross-Border DTAA

PE risk analysis, withholding optimization, MLI applicability.

Disputes & Appeals

CIT(A), ITAT, High Court representation in tax matters.

What We Cover

Key Highlights

Entity selection — Pvt Ltd, LLP, OPC, Section 8 tax comparison

Section 115BAA — 22% concessional regime

Section 115BAB — 15% for new manufacturing

Section 80-IAC — Startup 100% deduction

Section 35 R&D weighted deduction

Section 80JJAA — additional employment

Transfer pricing — Section 92-92F compliance

Cross-border tax — DTAA, GAAR, MLI

M&A tax — slump sale vs share sale vs amalgamation

Group restructuring and demerger

Holding-subsidiary tax efficiency

Our Process

How We Help You

A straightforward, transparent path from first call to resolution.

1Tax Diagnostic

Current entity structure, tax position, opportunities.

2Structuring

Recommend entity / transaction / group structure changes.

3Implementation

File necessary forms, restructure entities, document transfer pricing.

4Ongoing Compliance

Quarterly reviews, board updates, annual assessments.

5Disputes

Where assessments / appeals arise, litigate strategically.

Legal Framework

Applicable Laws & Regulations

Key statutes, rules and judicial precedents that govern this service.

Income-tax Act — Section 115BAA / 115BAB

Concessional corporate tax regimes.

Section 80-IAC

Startup deduction (3 of 10 years).

Sections 92-92F

Transfer pricing rules.

Section 95-102 (GAAR)

General Anti-Avoidance Rules.

Avoid These Mistakes

Common Pitfalls

Costly errors we routinely help clients fix — or better, avoid altogether.

Inappropriate 115BAA Election

Section 115BAA election forfeits various deductions. Election should be after detailed analysis.

TP Documentation Gaps

Missing TP study during related-party transactions invites adjustments and penalty.

GAAR-Triggering Structures

Pure tax-driven structures without commercial substance attract GAAR.

PE Risk in Cross-Border

Indian agents / dependent operations may create PE — exposing foreign principal to Indian tax.

FAQs

Common Questions

Everything you need to know before you begin

Compute tax under both regimes — old (with deductions) and new 115BAA (22% flat). For most stable companies, 115BAA is beneficial. Election is irrevocable.

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