Cross-Border Outbound
M&A Tax Structuring
End-to-end tax advisory for Indian entities acquiring foreign businesses. Comprehensive execution spanning 16 workstreams across five phases—from jurisdiction analysis to exit modelling.
HoldCo Optimisation
Strategic jurisdiction analysis for offshore holding companies. We evaluate Netherlands, Singapore, UAE, and GIFT IFSC to design optimal DTAA/MLI mapping and funding architecture.
Transaction Structuring
Precision execution of 12.5% LTCG optimisation, Section 47/70 tax-neutral transfers, Section 94B thin-cap mitigation, and highly efficient dividend repatriation design.
Contemporaneous Defence
Structuring recommendations are never delivered without robust, contemporaneous defence mechanics, embedding GAAR, PPT, POEM, and Pillar 2 GloBE ETR analysis from Day 1.
Core Advisory Deliverables
Our M&A tax practice manages the entire acquisition lifecycle—ensuring tax efficiency, regulatory compliance, and post-merger integration resilience.
Pre-Transaction Planning
In-depth jurisdiction analysis for HoldCo deployment (Netherlands, Singapore, UAE, GIFT IFSC), exhaustive DTAA/MLI treaty mapping, and precise FEMA/ODI route selection.
Tax Due Diligence
Comprehensive target and acquirer DD covering direct/indirect tax liabilities, Pillar 2 GloBE ETR exposure, legacy TP framework review, and stamp duty assessments.
Transaction Structuring
Mathematical modelling to achieve 12.5% LTCG optimisation, leveraging Section 47/70 for tax-neutral transfers, managing Section 94B thin-cap rules, and designing tax-efficient dividend repatriation.
Anti-Avoidance & Defensibility
Proactive risk mitigation delivered through contemporaneous GAAR and Principal Purpose Test (PPT) defensibility memos prepared prior to deal execution.
Post-Acquisition Integration
Establishing a robust Transfer Pricing architecture from Day 1, structuring POEM risk mitigation protocols, and deploying a unified compliance calendar.
Exit Planning
Forward-looking exit route modelling mapping up to 6 distinct scenarios, ensuring maximum shareholder value realization and minimizing friction upon future divestment.
Who Needs Cross-Border M&A Advisory?
Our outbound structuring practice is utilized by large Indian corporates and institutional investors seeking tax efficiency and regulatory certainty when acquiring overseas assets.
| Client Profile | Indicative Scale | Strategic Imperative & Solutions |
|---|---|---|
| Indian Manufacturing MNEs | ₹2,000 Cr+ turnover | Acquiring foreign targets to secure global supply chains, absorb advanced manufacturing technology, or establish direct market entry in the EU/US. |
| Indian IT / Digital Companies | Revenue USD 500M+ | Acquiring overseas SaaS platforms, product companies, or high-value intellectual property (IP) portfolios requiring complex DEMPE alignment. |
| PE / VC Funds (India-focused) | AUM USD 250M+ | Executing outbound platform acquisitions through sophisticated offshore holding structures to optimize capital flows and future exits. |
| Promoter Groups & Family Offices | Net worth ₹500 Cr+ | Structuring international asset diversification, navigating FEMA LRS frameworks, and strictly managing individual and corporate POEM risks. |
Implementation & Compliance
We do not stop at the advisory memo. Strategix executes the necessary filings and coordinates seamlessly across interconnected tax and regulatory frameworks.
| Service Area | Filings & Cross-Vertical Connections |
|---|---|
| Foreign Remittance | Form 15CA, 15CB, and Form 67 (Foreign Tax Credit) filings for outbound capital deployment. |
| FEMA / ODI Reporting | Strict compliance with Overseas Direct Investment guidelines, including ODI Part I/II/III, FC-GPR, and FC-TRS reporting. |
| Treaty Claims | Execution of Form 10F and Form 49D (TRC) to secure and defend DTAA benefits. |
| Global Tax Alignment | Vertical 11 Vertical 13 Deep integration with OECD Pillar Two multi-jurisdiction ETR thresholds and post-acquisition Transfer Pricing synchronization. |
| Carbon Tax Integration | Vertical 07 Vertical 10 If acquiring European industrial targets, embedding EU CBAM compliance and Green Bond transition finance into the acquisition model. |
Every referral begins with a confidential,
no-obligation assessment.
CA firms, law firms and professional services partners — contact Shreyansh Verma directly to discuss referral arrangements, co-advisory engagements, or a specific client mandate.