Treaty interpretation, withholding tax optimization, and Permanent Establishment risk management across 90+ jurisdictions. We ensure you pay the right tax — only once.
Double Taxation Avoidance Agreements (DTAAs) allow taxpayers to claim reduced withholding tax rates, treaty benefits on business profits, and foreign tax credits. However, treaty benefit claims require strict documentation and anti-avoidance compliance.
Without proper DTAA structuring, cross-border payments (royalties, dividends, interest, technical fees) can suffer excessive withholding tax — often 20-40% instead of the treaty rate of 5-15%. Additionally, Permanent Establishment (PE) exposure can shift tax residency and trigger unexpected tax liability.
SilverSiX provides end-to-end DTAA advisory — from TRC procurement and Form 10F filing to Limitation of Benefits (LOB) analysis and PE risk mitigation.
Deep-dive analysis of applicable DTAAs to identify the most tax-efficient structure for your cross-border transaction.
Evaluation of Permanent Establishment exposure for foreign companies operating in India and Indian companies abroad.
Procurement of Tax Residency Certificate and preparation of Form 10F for treaty benefit claims.
Structuring payments to minimize withholding tax under treaty rates and securing lower TDS certificates.
Proactive compliance with GAAR, SAAR, and treaty-specific anti-avoidance provisions.
Optimization of foreign tax credits under Section 90/91 to eliminate double taxation.
We map the nature of payment, payer/payee jurisdictions, and business substance to identify applicable treaties.
Comparison of domestic vs. treaty withholding rates, including MFN and protocol amendments.
Assessment of fixed place, service, and dependent agent PE exposure with mitigation recommendations.
TRC procurement, Form 10F preparation, and lower TDS certificate applications under Section 197.
LOB, PPT, and beneficial ownership analysis to pre-empt tax authority challenges.
Foreign Tax Credit optimization and repatriation planning to minimize global tax leakage.
| Deliverable | Description | Timeline |
|---|---|---|
| DTAA Structuring Memo | Treaty analysis, rate comparison & PE risk | Week 1 |
| PE Risk Report | Fixed place, service & DA PE assessment | Week 2 |
| TRC Application | Coordination with foreign tax authority for TRC | Week 2–4 |
| Form 10F | Prepared and filed for treaty benefit claim | Week 3 |
| Section 197 Application | Lower TDS certificate from Assessing Officer | Week 3–5 |
| LOB Compliance Note | Beneficial ownership & substance documentation | Week 3 |
| FTC Computation | Form 67 + foreign tax credit working | Week 4 |
| Repatriation Blueprint | Tax-efficient fund-flow structure | Week 4 |
Book a confidential discovery call with our advisory team. We assess your situation and outline a clear execution roadmap within 48 hours.
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