Management Trainee - International Taxation

Role & responsibilities :

International Tax Advisory

• Assist in advising clients/business teams on the Indian tax implications of cross-border transactions.
• Analyse transactions involving Indian and overseas entities and identify applicable tax implications.
• Assist in structuring cross-border transactions from an Indian tax perspective.
• Analyse the applicability of Double Taxation Avoidance Agreements (DTAAs) and domestic tax provisions.
• Assist in preparing tax opinions, advisory notes, technical memos, and presentations.
• Research and interpret provisions of the Income-tax Act, DTAAs, rules, circulars, notifications, and judicial precedents.

Withholding Tax

• Analyse withholding tax implications under Section 195 of the Income-tax Act for payments made to non-residents.
• Evaluate applicability of tax treaty provisions and determine appropriate withholding tax rates.
• Assist with Form 15CA/15CB requirements and related documentation.
• Support applications and correspondence relating to lower/nil withholding tax certificates, wherever applicable.
• Review agreements, invoices, and transaction documents to determine appropriate tax treatment.

Treaty & Permanent Establishment Analysis

• Assist in analysing Permanent Establishment (PE) exposure under applicable tax treaties.
• Evaluate treaty concepts such as Business Profits, Fees for Technical Services (FTS), Royalties, Interest, Dividends, and Capital Gains.
• Assist in analyzing residential status, treaty eligibility, beneficial ownership, and limitation of benefits considerations.
• Research and summarize relevant treaty positions and judicial precedents.

Transfer Pricing

• Support transfer pricing assignments involving international transactions and inter-company arrangements.
• Assist in analyzing inter-company agreements and related-party transactions.
• Support preparation/review of transfer pricing documentation and economic analyses.
• Assist with benchmarking and analysis of Arm's Length Price (ALP).
• Coordinate with transfer pricing teams on matters involving cross-border transactions.

Tax Compliance & Litigation Support

• Assist in international tax compliance and related reporting requirements.
• Support responses to income-tax notices, assessments, audits, and departmental queries.
• Assist in preparing submissions, factual summaries, legal research, and supporting documentation for tax proceedings.
• Track relevant tax litigation and judicial developments affecting international transactions.

Tax Research & Regulatory Updates

• Conduct research on developments in Indian international tax law, OECD guidelines, BEPS, Pillar One, Pillar Two, and global tax developments.
• Monitor amendments to the Income-tax Act, Finance Act, tax treaties, rules, circulars, and notifications.
• Prepare concise research notes and internal updates on significant tax developments.
• Analyze relevant rulings from Indian courts and tax tribunals and assess their business implications.

Qualifications

Chartered Accountant (CA) Qualified.

• 02 years of post-qualification experience preferred; freshly qualified CAs with a strong interest in International Taxation are encouraged to apply.
• Strong academic understanding of direct taxation and accounting.
• Prior exposure to international taxation, transfer pricing, tax litigation, or tax advisory during articleship will be an advantage.

Technical Skills

The candidate should have a good understanding of:

• Indian Income-tax Act
• Section 195 – Tax Deducted at Source on payments to non-residents
• DTAA / Tax Treaty provisions
• Permanent Establishment
• Royalties and Fees for Technical Services
• Business Profits
• Tax Residency and Treaty Eligibility
• Transfer Pricing fundamentals
• OECD Model Tax Convention
• OECD Transfer Pricing Guidelines
• BEPS framework
• Pillar One and Pillar Two
• Form 15CA / 15CB
• International tax compliance and reporting

Desired Skills

• Strong tax and legal research capabilities.
• Ability to interpret and apply complex tax provisions.
• Excellent analytical and problem-solving skills.
• Strong written and verbal communication.
• Ability to prepare high-quality tax memos, presentations, and reports.
• Strong MS Excel and PowerPoint skills.
• Excellent attention to detail.
• Ability to manage multiple assignments and meet deadlines.
• Commercial understanding and ability to connect tax provisions with business transactions.
• Proactive approach and willingness to continuously learn.

Key Competencies

• International Tax Advisory
• Tax Research
• DTAA Interpretation
• Cross-Border Taxation
• Withholding Tax
• Transfer Pricing
• Analytical Thinking
• Legal & Technical Interpretation
• Client/Stakeholder Management
• Business Acumen
• Attention to Detail
• Communication Skills