Case study 1
A currency deposit that never reached the home return
The client had held foreign-currency deposits in India for a long time and had never mentioned them, on the honest understanding that nothing was taxed on them. The Indian treatment was not the issue. He lived elsewhere, that country taxed him on worldwide income, and the account was reportable there whatever India did. We established the open years, took the interest year by year from the bank’s certificates, converted it for each year, and brought both the income and the account reporting up to date through the disclosure route that fitted his facts. The engagement produced a filed set of years and a reporting position for the future.
Case study 2
Choosing currency rather than rate before the deposit is made
The client was comparing a rupee account and a foreign-currency deposit on their advertised rates alone. That comparison leaves out the part which usually decides the outcome, namely the currency he would eventually spend the money in. We set the two out on the same basis: what each does to exchange exposure, what each assumes about where the funding comes from, and what each means when the money is later taken out of India. The engagement produced a written comparison on his own facts and a funding route documented from the start, so the origin of the deposit would not have to be reconstructed later.
Case study 3
A deposit funded from a balance of mixed character
The deposit had been made from a balance that included both money brought in from abroad and receipts arising in India. At maturity the client asked for the funds abroad and the bank stopped, because it could not tell from its own records what it was holding. The work was to go back to the credits that had formed the balance, separate them by origin, and evidence each with the original advices. The engagement produced a schedule tying the deposit to its sources, a resolved position on the portion in question, and a release the bank was able to make on the documents.
Case study 4
A deposit still running when the holder came back to India
The client had returned to India with a deposit still running and had told nobody, on the basis that the deposit itself had not changed. The status behind it had. We established the date of return from the evidence of the move as a whole, applied it to the deposit and to the operating accounts separately, and made sure the return for the year of return treated the interest on the same footing as the bank records did. The engagement produced a dated change of status, corrected accounts, and a filing consistent with both.
Case study 5
Exchange movement recorded year by year for the home return
The deposit was in one foreign currency, the client’s home return was in another, and nobody had decided how the interest should be brought across. Different answers had been used in different years, which is what makes a file hard to defend later. We set a single method, applied it consistently to every open year, and documented it so that it could be repeated. The engagement produced a year-by-year schedule of interest in the reporting currency, corrected returns where earlier figures had been wrong, and a method note that removed the question for future years.
Case study 6
An inherited deposit that beneficiaries abroad could not release
A deposit formed part of an Indian estate and the beneficiaries lived outside India. They had assumed the bank would simply pay them where they lived. The obstacle was that the deposit’s own terms, the account structure and each beneficiary’s status all had to be dealt with, and none of them followed automatically from the will. We worked through the estate documents, established each beneficiary’s position under the exchange-control law, and put the funds into accounts from which a transfer was permitted. The engagement produced a documented route from the estate to each beneficiary and transfers the bank processed without further query.
Case study 7
Treaty Relief Claimed on a Cross-Border Estate
The estate article can extend a proportionate credit where the two systems would otherwise both tax the same asset. Claiming it requires a valuation and a disclosure the estate may not expect to make.
Read how this one runs
Case study 8
One Salesperson Abroad, and a Corporate Filing Obligation
A single employee with authority to conclude contracts can create a taxable presence for the whole company. The review tests what the person actually does against the treaty article, and where a presence exists, works out what profit is attributable to it.
Read how this one runs
