Raghav Gupta — UAE & India international, cross-border tax & TP
Fellow Chartered Accountant, looking after UAE and India cross-border tax, with transfer pricing, BEPS and international tax behind it.
- 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 · UAE & India International Tax, Cross-Border Tax & Transfer Pricing · Legal Quotient Consultants
Files that run between the UAE and India
FCA (India)
Raghav Gupta is a Fellow Chartered Accountant who looks after UAE and India cross-border tax at Legal Quotient Consultants, from Delhi. His files are the ones that move between the two countries: a person whose residence changes, a business earning in one and owned from the other, and a group whose intercompany prices have to stand up in both.
He has been a partner in the practice's transfer pricing work since at least 2014, and his published writing from that year sets out the transfer pricing issues in royalty payments between related companies. He also teaches, as a faculty member on transfer pricing and international tax.
- Delhi
- UAE and India
- Transfer pricing since 2014
Areas of expertise
Transfer pricing partner
leading the practice's transfer pricing work since at least 2014, including for professionals whose own clients have international or specified domestic transactions.
BEPS and international tax
the base erosion and profit shifting rules that now shape how a group documents and prices its cross-border dealings.
Author and faculty
published on transfer pricing in royalty payments (2014), and a faculty member teaching transfer pricing and international tax.
Qualifications
Fellow Chartered Accountant (India)
Fellow member of The Institute of Chartered Accountants of India (ICAI) — the senior grade of membership of India's statutory body for chartered accountants.
What Raghav handles
UAE and India residence
which country a person or company is resident in, and what the treaty does when both claim them.
Benchmarking and method selection
the comparables and the method that support an intercompany price.
Local file and master file
the documentation set that supports a group's pricing policy under examination.
Royalties and service charges
payments for intangibles and intra-group services, the two areas where an Indian tax officer looks first.
Who Raghav works with
UAE residents with Indian income
People living in the UAE with property, investments or business income in India.
Groups across the UAE and India
Companies with related entities in both countries and intercompany charges between them.
Professional firms
Chartered accountants and advisers whose own clients have international or specified domestic transactions.
Disclosures
Professional status. The designations on this page are Raghav 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 questions comes into this file
Readers arrive here searching for international tax questions, and raghav Gupta is what the page is about. Below: who it catches, what has to be filed, and what it costs — quoted in writing, before anything is done.
People also search for: tax systems · the tax experts · what is price transfer · 2026 tax information · declare foreign assets.
What these engagements turn on
A first year abroad handled in both countries at once
Someone moved partway through a year and had income on both sides of the move. The work began by establishing when residence actually changed, because everything else follows from that date and it is a question of facts rather than of travel documents. The two returns were then prepared together rather than in sequence, so the income split and the relief claimed on one side match what the other side reports. The engagement produced a pair of returns that agree with each other, and a written note of the position taken on the date with the evidence for it.
Withholding at source recovered by filing the return
A non-resident had tax withheld on income arising in a country they do not live in. Withholding of this kind is often applied to a gross amount rather than to the profit, so it routinely exceeds what is finally owed, and the only way to establish the real figure is to file. The work was to gather the costs that reduce the taxable amount, evidence them to the standard a reviewer expects, and file the return that computes the liability properly. The engagement produced a filed return and a claim for the excess that had been held at source.
Accounts abroad reported once the reporting test was explained
The client had held accounts outside their country of residence for years and had assumed that reporting the income settled everything. It does not: the account itself is reportable separately from the income it produces, under rules with their own tests and their own filings. The work was to establish which accounts met the test in which years, gather the statements to support them, and prepare the reports alongside the returns. The engagement produced a complete set of filings and a standing checklist the client uses each year without needing to ask again.
A payment across a border characterised before it was taxed
A company was about to make a regular payment to a related party in another country and asked what rate to withhold. The prior question was what the payment was: the characterisation decides which rule reaches it, and the parties' own invoice description binds nobody. The contract and the actual dealings between the two companies were read before any rate was discussed. The engagement produced a written characterisation with the reasoning behind it, the withholding treatment that follows from it, and wording for the agreement that matches what is actually happening.
A company's cross-border payroll tested employee by employee
The employer had one arrangement covering everybody and wanted confirmation it was right. It was not so much wrong as undifferentiated: the answer depends on where each person is physically working, what their contract says and which entity bears their cost, and those differed across the group. Each employee was tested separately. The engagement produced remittances corrected going forward, a schedule of the historic position for the employer to take advice on, and a test their own staff apply when the next person moves.
A second opinion that left the original filing standing
A client brought a return prepared elsewhere for a view, expecting to be told it was wrong. Read against the documents, the position taken held up, including one treatment that looked unusual and turned out to be the correct reading for that year. The useful output was not a new filing but a written note of why the position stands and what would have to change for it to stop standing. The client kept it for the file. Telling somebody that their existing adviser got it right is part of the work.
Inheriting Property in India While Living Abroad
India does not tax the inheritance itself, but the later sale and the money leaving the country both have positions of their own. The file establishes the cost base to use on that sale and what the remittance will require.
Read how this one runsOptions Granted in India and Exercised Elsewhere
Where the grant, the vesting and the exercise happen in different countries, each may claim part of the same gain. Apportioning it across the period worked is what prevents the whole amount being taxed twice.
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
Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.
Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.
- 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
- 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
