13 Specialist
Tax & Regulatory
Advisory Verticals
Big 4–benchmarked specialist advisory across 13 integrated verticals. Every engagement carries dual ITA 1961 & 2025 citation, embedded Pillar 2 GloBE analysis, and contemporaneous GAAR / PPT / POEM defensibility as standard.
Income-tax Act, 2025
Consolidates 700+ sections to ~536 across 16 Schedules. Key changes: Section 233 demergers, 49% Section 79 threshold, multi-year ALP, 13 independent AE tests. Every Strategix deliverable carries dual ITA 1961/2025 citations.
Finance Bill 2026
MAT at 14% as final tax; brought-forward credit capped at 25%. Interest disallowance on dividend income for new-regime companies. Schedule IV toll manufacturing exemption framework introduced.
OECD Pillar 2 / GloBE
EU, UK, Singapore and Hong Kong regimes are live. India QDMTT expected imminently. Indian tax holidays can push ETR below 15%. Substance-based planning now replaces traditional rate-based planning.
All 13 Service Verticals
From cross-border M&A to CBAM compliance — our 13 verticals are integrated by design, not by accident.
India Entry & Expansion Strategy Advisory
The only productised, state-by-state investment advisory in the Indian market. Covers all 28 states and 8 Union Territories with individual investment handbooks, 54 central government schemes, 201 investment opportunity cards across 71 sectors, and an interactive incentive stacking calculator. Scored 53/60 in independent competitive benchmarking.
Explore Service
Cross-Border Outbound M&A Tax Structuring
End-to-end advisory for Indian entities acquiring foreign businesses. 16 workstreams across five phases — pre-transaction, due diligence, transaction structuring, post-acquisition and exit planning. HoldCo jurisdiction analysis (Netherlands, Singapore, UAE, GIFT IFSC), DTAA/MLI mapping, FEMA/ODI compliance, Pillar 2 ETR modelling, and 6-scenario exit planning.
Explore Service
GIFT City IFSC Advisory
Comprehensive advisory across all 11 IFSC verticals — banking (IBUs), capital markets, fund management, insurance, global treasury, aircraft/ship leasing, bullion, FinTech and sustainable finance. Section 80LA NPV-optimised year selection, IFSCA licensing and Pillar 2 QDMTT interaction analysis.
Explore Service
Inbound FDI Structuring
Advisory for foreign investors entering India. Entity form selection (subsidiary, branch, LLP, liaison office), FEMA/FDI compliance, three-scenario ETR modelling (conservative, base, aggressive), capital structure optimisation, TP architecture, PE risk management, and supply chain tax planning.
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GCC India Advisory
India’s 1,700+ GCCs employ 1.9M professionals. Covers entity setup, Day-1 readiness (100+ point checklist), TP characterisation (cost centre to entrepreneurial entity), safe harbour elections (18% ITeS, 21–24% KPO, 24% R&D), workforce structuring, PE risk mitigation and IP migration. Ranked #1 above Dhruva and KPMG (86%).
Explore Service
Cloud & AI Tax Advisory
Specialist advisory at the intersection of digital economy taxation and international tax. SaaS/IaaS/PaaS payment characterisation (royalty vs. FTS vs. business profits), Pillar 2 GloBE and SbS Safe Harbour for IP-intensive tech structures, TP for cloud cost allocation, EU ViDA compliance, EU AI Act implications, and a proprietary 14-product Cloud & AI tax map.
Explore Service
CBAM & Carbon Credit Tax
Advisory for Indian exporters facing EU CBAM (definitive phase from 2026) and UK CBAM. Facility-level embedded emissions computation, quarterly CBAM reporting, sector playbooks for steel, aluminium and cement, carbon credit tax characterisation (business income vs. capital gains), CCUS deductibility and India CCTS. Handbook V5.1 scored 9.7/10.
Explore Service
Global Talent & Cross-Border Workforce Tax
Advisory for internationally mobile workforces. Budget 2026 Global Expert Exemption, expatriate tax structuring and equalisation, ESOP/RSU cross-border apportionment (grant-by-grant models), service PE mitigation (183-day tracking), FAST DS 2026 remote work framework, and social security optimisation across a 20+ SSA network. Handbook V4.0 scored 9.7/10.
Explore Service
Data Centre REIT / InvIT Monetisation
Advisory for AAA-rated corporates monetising data centre portfolios through REITs and InvITs. DC-to-REIT conversion (Section 115UA pass-through, Section 47(xvii) CGT deferral), InvIT formation with elevated leverage up to 70%, cross-border investor tax & FEMA, CPSE REIT (Budget 2026), and tax holiday + REIT dual-benefit structuring. Handbook V5.2 (22,000+ words).
Explore Service
Green Bond & Sustainability-Linked Financing Tax
Advisory at the intersection of tax and sustainable finance. Green bond tax structuring (SEBI framework), carbon-backed financing (CCTS, CCUS), sustainability-linked loan (SLL) tax planning, CBAM transition finance, infrastructure green financing via GIFT IFSC exchanges, and Second Party Opinion tax review. Integrated with CBAM practice.
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Pillar Two Readiness & QDMTT Advisory
10-service framework (6 core + 4 closing Big 4 gaps). GloBE ETR modelling, QDMTT readiness, tax holiday–GloBE interaction (Section 80LA, 80-IA, 10AA, 115BAB), SbS Safe Harbour, GIFT City GloBE strategy, financial statement advisory (IAS 12), data & technology strategy with Big 4 platform benchmarking, and QRTC advisory. Handbook V3.1 verified against 29 parameters.
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Toll Manufacturing & Bonded Zone Tax Advisory
Advisory for non-resident capital goods providers and Indian contract manufacturers. Finance Act 2026 Schedule IV exemption, TP safe harbours (12% auto components incl. Li-ion, 24% contract R&D), component warehousing (Rules 99–100), customs bonded manufacturing (Section 65), FEMA structuring, GAAR resilience, GST job work and Pillar 2 interaction. Handbook V4.1 (15 appendices).
Explore Service
Transfer Pricing Advisory
Full-lifecycle TP advisory: policy design, benchmarking, three-tier documentation (Local File, Master File, CbCR), safe harbour elections (March 2025 updated margins), APA strategy (unilateral/bilateral), secondary adjustment management (Section 92CE, SOFR + 300 bps), dispute resolution (TPO, DRP, ITAT), and Pillar 2–CbCR alignment. ITA 2025 introduces multi-year ALP (Section 161) and 13 AE tests (Section 162). 50+ judicial precedent library.
Explore ServiceWhy Senior-Partner-Led Specialist Firms Outperform
Three non-negotiable principles define every Strategix engagement — not just our marketing.
Dual-Act Fluency
Every deliverable carries dual ITA 1961 and ITA 2025 citations as standard. The Income-tax Act 2025, effective 1 April 2026, is the most significant rewrite in 65 years. Every Strategix memo is ready for the transition.
Pillar 2 / GloBE Embedded
Integrated GloBE analysis is embedded into every structuring recommendation — not raised after the fact. Indian tax holidays can push ETR below 15%, triggering top-up tax. We model this from Day 1.
Anti-Avoidance Defensibility
GAAR, PPT and POEM defensibility is a standard deliverable — not an afterthought. Every structure is tested against all three frameworks before the engagement closes, with contemporaneous documentation on delivery.
Big 4 Quality, Specialist Agility
Every deliverable scored 86–9.7/10 in independent competitive benchmarking. Delivered with direct partner access and responsiveness of a specialist firm. No junior associates on substantive structuring decisions.
Seamless Collaboration
Referral partners retain the client relationship. Strategix provides the specialist tax structuring layer. Co-branding, revenue sharing and clear scope delineation — transparently structured for every engagement.
Regulatory Currency
A quarterly regulatory change log is maintained across all 13 verticals. Clients receive proactive alerts for changes affecting their structures. The Pillar Two handbook is verified against 29 independent parameters.
Our Six-Step Engagement Methodology
Every Strategix engagement follows this consistent framework — from first briefing to annual health check.
Regulatory Mapping
Dual ITA 1961/2025 citations; FEMA, Companies Act, DTAA/MLI, Pillar 2, customs, GST.
Risk Identification
Structured checklists for GAAR, PPT, POEM, indirect transfer, thin-cap and Pillar 2, validated against judicial precedent.
Quantitative Modelling
ETR scenarios, capital gains, dividend cascading, MAT credit and Pillar 2 top-up tax — multi-scenario outputs.
Structure Design
Optimal architecture incorporating jurisdiction, funding, treaty, FEMA and exit planning in one integrated memo.
Documentation
Board resolutions, investment memos, substance plans, GAAR/PPT/POEM assessments and TP studies on delivery.
Ongoing Monitoring
Compliance calendars, annual health checks, regulatory change alerts and Pillar 2 ETR tracking throughout lifecycle.
When to Refer to Strategix
These client situations are strong referral triggers. Each links directly to the relevant service vertical.
Client planning to invest in India / expand to new state
Client wants to compare states / avail PLI / claim SGST
Client planning an overseas acquisition
Foreign company setting up in India
Client receiving TP adjustment or notice
GIFT City entity setup or expansion
Steel / aluminium / cement exporter to EU
Data centre monetisation or REIT listing
Client deploying AI or cloud at scale
Expatriate or ESOP structuring complexity
MNE group €750M+ consolidated revenue
Toll or contract manufacturing arrangement
End-to-End Compliance Capabilities
Beyond advisory, Strategix handles the full compliance filing cycle across all verticals.
| Category | Forms & Filings | Applicable Verticals |
|---|---|---|
| Transfer Pricing | 3CEB, 3CEAB, 3CEAA, 3CEAC, 3CEAD, 3CEFA, 3CED | All verticals with intercompany transactions |
| Foreign Remittance | 15CA, 15CB, Form 67 (FTC) | M&A, FDI, GIFT City, Toll Manufacturing |
| FEMA / ODI Reporting | ODI Part I/II/III, FC-GPR, FC-TRS | M&A, FDI, GIFT, GCC |
| Treaty Claims | Form 10F, Form 49D (TRC) | All cross-border verticals |
| Income Tax Returns | ITR (corporate and individual) | All verticals |
| SEBI / IFSCA | REIT/InvIT filings; IFSCA returns | DC REIT, GIFT City IFSC |
| CBAM / Emissions | EU CBAM quarterly reports; CCTS returns | CBAM & Carbon Credit |
| GST | GSTR-1/3B; e-invoicing; e-way bill | Toll Mfg., FDI, M&A asset transfers |
| State Investment Incentives | Single window applications; SGST claims; PLI filings | India Entry & Expansion |
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.
Income-tax Act, 2025 takes effect from 1 April 2026. All information current as of March 2026.