Abhinav Gupta — India international, cross-border tax & TP
Chartered Accountant, looking after India cross-border tax: Indian returns with a second country in them, and the transfer pricing that sits beside intercompany work.
- 15+Years of the founder's cross-border experience
- 18,000+Clients served across our offices in India, the USA, Canada and the UAE
- 5.0Google rating
- 4Global offices — India, USA, Canada & UAE
Director · India International Tax, Cross-Border Tax & Transfer Pricing · Legal Quotient Consultants
The Indian side of a file that has two countries in it
CA (India)
Abhinav Gupta is a Chartered Accountant who looks after India cross-border tax at Legal Quotient Consultants. His files are the ones where India is one of the two countries: a resident with income or assets abroad, a non-resident with income in India, or a business with a related party on the other side of a border.
His background is international taxation and transfer pricing, including transfer pricing compliance and the disputes that follow when an intercompany price is questioned, and he has also supported businesses setting up in Canada.
- India cross-border tax
- International taxation
- Transfer pricing
Areas of expertise
International taxation
residence, source and treaty relief on files that are taxed in India and somewhere else at the same time.
Transfer pricing compliance and litigation
the documentation an intercompany price needs, and the case that has to be made when a tax authority disputes it.
Setting up in Canada
support for Indian and other businesses starting operations in Canada, and the tax questions that come with the first year.
Qualifications
Chartered Accountant (India)
Member of The Institute of Chartered Accountants of India (ICAI), the statutory body that regulates the chartered accountancy profession in India. Membership follows the Institute's examinations and a period of practical training.
What Abhinav handles
Indian returns with foreign income
residents who earn, hold or sell abroad, and the disclosure an Indian return needs when they do.
Non-resident income in India
rent, interest, capital gains and business income earned in India by someone who no longer lives there, and the tax deducted at source before it reaches them.
Treaty relief
the credit or exemption the treaty allows, claimed once and in the right country.
Intercompany pricing
where an Indian company transacts with its parent or a sister company abroad, and the documents that support the price.
Who Abhinav works with
Non-resident Indians
NRIs with rent, interest, capital gains or business income in India.
Returning residents
People moving back to India with income and assets abroad.
Indian companies
Businesses keeping their income tax and TDS filings current.
Businesses setting up in Canada
Indian and other companies opening a Canadian operation and its first-year filings.
Disclosures
Professional status. The designations on this page are Abhinav Gupta's own, held personally. Legal Quotient Consultants is not a licensed public accounting firm in Ontario, and nothing here says otherwise.
Scope. This practice prepares and files tax returns and supporting documentation, and represents clients with the revenue authorities. It does not perform audit or assurance engagements.
General information. Nothing on this page is advice for a particular situation. Book a consultation and the position is worked out on the facts of your file, with the fee agreed in writing before any work starts. Call +1 (416) 619-0068.
Profile last reviewed September 2026.
Where international tax accountant comes into this file
The subject here is abhinav Gupta, which is what people mean when they search for international tax accountant. This page covers who it applies to, the filings it produces, and the fixed fee agreed before work begins.
Cross-border tax case studies
A management charge between a parent and its overseas subsidiary
The group charged an annual management fee that had been set once and never revisited. Review began with what the parent's staff actually did for the subsidiary, month by month, rather than with the charge itself. Several of the services described in the invoice had stopped years earlier, and two that were genuinely being provided appeared nowhere in it. The work produced a rewritten functional analysis, a charge built from the services actually performed, and an intercompany agreement signed to match. The group now holds a dated file that explains the basis of the charge without anyone having to remember it.
A cost-plus arrangement tested against what it actually covered
A back-office company billed its overseas parent on a cost-plus basis, with the cost base assembled by the bookkeeper from whatever sat in the ledger. The technical question was not the mark-up but the base: pass-through costs and a shareholder activity had both been swept into it. The work consisted of separating the cost categories, documenting why each belonged in or out, and recording the search for comparable arrangements that supported the mark-up applied. It produced a revised cost base, a contemporaneous memorandum, and a schedule the group updates each year rather than rebuilding under pressure.
A dual-resident company that had two tax homes on paper
The company was incorporated in one country and managed from another, so both treated it as resident. The enquiry arrived as a question about which return came first. The work was to establish where the key management decisions were in fact taken, gather the board minutes, travel records and correspondence that evidenced it, and apply the treaty tie-breaker to that evidence rather than to the incorporation certificate. The engagement produced a residence memorandum, a corrected filing position in both countries, and a note of the governance changes needed if the group wanted the position to stay stable.
A query letter about related-party pricing answered from the file that existed
The letter asked how prices charged to an associated company had been determined. The group's instinctive answer, before we were engaged, was that the figures had always been reasonable. The work was to assemble what genuinely existed at the time — agreements, invoices, correspondence and the working papers behind the original calculation — and to describe plainly where the record was thin. What it produced was a written explanation of the method used, the documents that supported it, and a clear statement of which parts had been prepared afterwards rather than contemporaneously.
A licence fee between group companies with no written terms
Software developed in one country was used by an affiliate in another, and a royalty had been booked each year by journal entry alone. Nothing recorded what was licensed, for how long, or on what terms. The work began by establishing who had developed the software and who had funded that development, since between them those determine who is entitled to the return it earns. It produced a written licence, a description of the functions and risks carried on each side, and a pricing note tying the royalty to that entitlement rather than to a figure chosen at year end.
A group restructuring reviewed before the entities were moved
The client came with a plan already drawn and asked for it to be implemented. Review took the plan apart in the other order: what each entity would do afterwards, who would own what, and which country would then have taxing rights over the profits. Two steps in the original sequence created a charge that a different ordering avoided, and one entity had no commercial purpose left once the rest was in place. The work produced a revised step plan, a memorandum recording the reasoning for each step, and the documents to be signed at the time rather than reconstructed later.
A Second Opinion on a Return Already Filed
A cross-border return prepared on one side only is usually right in isolation and wrong in combination. The review checks residence, source and relief in that order, and says plainly whether an amendment is worth making.
Read how this one runsDeduction at Source on Deposit Interest, Recovered
Where the treaty rate is lower than what was deducted, the difference comes back through a return rather than at source. The file establishes entitlement and files for the years still open.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Performance income is taxed where earned — Regulation 105 in Canada, withholding agreements in the U.S. — with special treaty articles overriding the usual rules.
Performance income is taxed where the performance happens, and the deduction is usually taken at source on the gross fee before expenses. Recovering the difference is a filing exercise in the other country, and it only works if the tour, the residency and the withholding certificates were documented while the work was being done.
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
