Outbound Investment Structuring

When an Indian group invests abroad, the holding jurisdiction, the financing, and the repatriation route shape the tax on profits and dividends and the FEMA position. The structure needs to work under the overseas-investment rules and the tax rules of both countries.

The firm designs the outbound structure across tax, FEMA, and treaty considerations — beyond the ODI compliance to the structuring decision itself.

Outbound investment structuring covers, including:

• The overseas holding jurisdiction and structure
• Financing and the repatriation route
• Tax efficiency on profits, dividends, and exit
• Compliance with the FEMA Overseas Investment Rules
• Treaty access and controlled-foreign-company considerations

1. 01

   Understand the plan

   Get the target, the objectives, and the funding clearly.

2. 02

   Design

   Model the structuring options across tax and FEMA.

3. 03

   Recommend

   Advise the efficient, compliant structure.

4. 04

   Implement

   Set up the structure and the ODI compliance.

PBT structures outbound investment efficiently and within the rules.

• A structure that works across tax and FEMA
• Efficiency on profits, dividends, and exit
• Compliant with the overseas-investment rules
• Joined up with the ODI compliance
• Scope, deliverables, and fees agreed in writing up front

• How is this different from ODI advisory?

  ODI advisory focuses on the FEMA route and reporting; outbound structuring is the design of the holding and financing structure across tax and FEMA.

• Do you consider the tax of the destination country?

  Yes — we consider both Indian and destination-country tax and the treaty between them, coordinating with local advisers where needed.

• How long does it take?

  Designing a structure takes a few weeks; implementation follows the transaction timeline.