Tax Planning & Restructuring

The single largest controllable cost on most Indian balance sheets is tax. By FY 2026-27, after a decade of regime changes — the new tax regime as default, the rationalised capital gains structure, the abolition of indexation for most assets, the corporate tax cuts under Section 115BAA / 115BAB, the new VDA regime, the Black Money Act, the General Anti-Avoidance Rules (GAAR), the simplified ITR forms, and the upcoming Direct Tax Code — the difference between an actively planned tax position and a passive one is no longer 5% or 10%. It is often 25-40% of the headline tax outflow over a 5-year horizon.

Tax planning is not tax evasion, and it is not aggressive tax avoidance either. It is the lawful structuring of transactions, ownership, and timing under Section 5 to 10 (charging and exemption), Section 115 (special rates), Section 47 (transactions not regarded as transfer), Section 50B (slump sale), Section 56(2) (deemed gift), Section 90/91 (DTAA), Section 80C-80U (deductions), Section 54-54GB (capital gains exemptions), and the Companies Act provisions on schemes of arrangement. It works because the law itself provides the levers — and most taxpayers don't pull them.

We do strategic tax planning for individuals, HNIs, family offices, owner-managed businesses and growing companies. The mandate is always written: lawful tax minimisation, GAAR-compliant, with audit-defence documentation and a 5-year cash-flow model.

Where Tax Planning Pays Off Most

• Individual & HNI Planning:: Old vs new regime decision modelled annually; 80C / 80D / 80CCD / 24(b) headroom maximised; capital gains under the new 12.5% regime planned across the financial year (March-vs-April booking); Section 54 / 54EC / 54F sequencing; HUF formation where beneficial.

• Owner-Managed Business Planning:: Salary vs dividend mix; Section 115BAA (22%) vs 25% / 30% rate; LLP vs Pvt Ltd choice; remuneration to partners (Section 40b); presumptive income (Section 44AD / 44ADA / 44AE) where eligible.

• Capital Gains & ESOP Planning:: Asset-class sequencing, indexation grandfathering election, Section 54EC bond windows, ESOP exercise timing, deferred-tax election for eligible startup ESOPs.

• Corporate Restructuring & M&A:: Slump sale (Section 50B), demerger (Section 2(19AA)), amalgamation (Section 2(1B)), share capital reduction, buy-back (Section 68 + Section 115QA), conversion (LLP-to-Pvt, Pvt-to-Public, OPC-to-Pvt) — all structured for tax neutrality where law permits.

• Family Office & Succession:: HUF, private trusts (revocable / irrevocable), Will + nomination architecture, family-investment-company (FIC), pre-emptive succession rather than reactive estate.

• Cross-Border Structuring:: DTAA tie-breaker, place-of-effective-management (POEM), permanent establishment, GAAR test, Mauritius / Singapore / Netherlands / UAE structuring within the post-2017 LOB regime.

• VDA / Crypto Strategy:: Section 115BBH 30% flat tax, Section 194S TDS, AIS reconciliation, exchange selection — limited but real planning levers.

Why Tax Planning Without Documentation Doesn't Survive Scrutiny

An idea that saves tax is not the same as a structure that survives a Section 143(3) scrutiny five years later. The structure must be documented — board resolutions, valuation reports, commercial rationale memoranda, GAAR pre-tests, and bank trail — at the time the transaction happens, not when the assessment notice arrives. We always pair planning with the documentation set the AO will eventually demand.