Case study 1
Substance file built for a Singapore holding company before an Indian payment
The company held an Indian investment and expected to claim treaty relief on a distribution, with little beyond a certificate behind it. We looked at what the Indian side actually tests: where decisions are taken, by whom, and with what assets and expenditure behind the activity described. We then built the file as the facts occurred — minutes, the record of where decisions were made, operating costs, the personnel — and identified the gaps that wording alone would not close. The engagement produced a dated substance file, a written note of the relief position it supports, and a list of the facts that would weaken it.
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Case study 2
Residency certificate and declaration put in place before the first payment
Relief had been claimed on the return each year while the payer deducted at the domestic rate meanwhile, so cash came back a year late every year. We changed the sequence rather than the claim: obtained the residency certificate for the year and prepared the declaration the payer required, both delivered before the first payment of the year was made. The engagement produced relief applied when the payment was made instead of reclaimed afterwards, a renewal calendar for both documents, and an Indian return that no longer carried a recovery claim at all.
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Case study 3
Indian residence position run for a professional who moved mid-year
A consultant took a Singapore engagement partway through a year while continuing to bill Indian clients, and had assumed the move settled the question. India applies its own residence test over its own year, so we counted presence from travel records, separated fees for work performed in India from fees for work performed outside it, and reached a position on status and on source separately. The engagement produced a documented status conclusion, an allocation of the year's fees by place of performance, and a filing scope for each country built on the same set of facts.
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Case study 4
Treaty position reopened on a notice and answered from existing records
Relief claimed in an earlier year was queried, and the question was whether anything stood behind the entity beyond its incorporation. We assembled what had existed at the time rather than what could be written now: board records, the people involved, the expenditure, the decision trail on the investment itself, and correspondence showing the transaction had been managed from where the company sits. The engagement produced a reply resting entirely on contemporaneous material, a schedule indexing each document to the point it supports, and a note of what to keep as the investment continues.
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Case study 5
Two returns reconciled for a consultant billing clients in both countries
Fees were being reported to each country on whatever figures that country's records produced, and the two did not agree. We rebuilt the year from the invoices: what was billed, where the work was performed, what was received after Indian deduction, and which of each country's periods the receipt fell into. The engagement produced a single reconciliation schedule feeding both returns, a relief claim resting on deduction certificates that match the income reported, and income figures the two filings now state identically.
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Case study 6
Excess deduction recovered after relief was refused at the time of payment
The payer applied the domestic rate because the declaration reached it after the payment had been processed. Nothing could be changed about that payment, so the work was recovery: compute the liability the treaty position actually produces, establish the tax borne from the deduction certificates, and claim the difference on the Indian return for the year. The engagement produced a filed return recovering the excess, corrected documentation lodged with the payer for later payments, and a short procedure the client now runs before each payment cycle.
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Case study 7
Three Account Types, Three Tax Answers
Interest on each is treated differently and the deduction at source follows the account rather than the person. Holding the wrong one for the purpose is a recurring and avoidable cost.
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Case study 8
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.
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