1. Flexibility in borrowing and corporate restructuring;
2. JV Private Equity Funding Bilateral
3. Agreements Tax Efficiency
4. Ease of entry and exit
5. Overseas Listing

Significance of SPV:

1. Participation Exemption:- Benefit of exemption in the SPV’s jurisdiction for dividend and capital gains coming from downstream investments on the fulfilment of certain conditions. Conditions basically include shareholding pattern, the jurisdiction of the parent entity and share of the holding.
2. IPR Regime: Specific deduction, exemptions, and incentives are available in some jurisdictions with regard to IPR holdings such as Patent Box Regime .i.e. concessional rate for royalty income in case of certain IPR’s and also deduction for certain cinematographic films given in the UK.
3. Withholding Tax provisions: Withholding tax exemptions on dividends, royalties, and interest.
4. Favourable Holding Company Regime: Lower income tax rates for holding companies under specific holding company regimes, existence of CFS provisions, Good Treaty Network.
5. Thin Capitalization Rules: Companies are said to be capitalized thinly when its capital comprise a greater proportion of debt equity. In such a case cash repatriation is possible by claiming tax deduction for interest on debt Our

Key point of our legal Services:

1. Advice and assist on entity structuring, capital structuring and regulatory approval process in the selected jurisdiction.
2. Advice on cross-border investment strategies including suggestions for obtaining optimal ownership structures for investing into a particular jurisdiction which includes setting up an international holding company, global sales company etc.
3. Assist in finalizing and review of the shareholders, joint venture and other business agreements or arrangements from tax perspective.
4. Identify and enhance tax and fiscal benefits including obtaining tax rulings in the selected jurisdiction.
5. Advice on tax credit claim in India and also Tax treaty implication.
6. Assist in obtaining approvals from Reserve Bank of India and also from the regulatory authorities