Corporate Tax Structuring & Planning

Overview

Effective corporate tax planning is not about aggressive avoidance — it is about ensuring that legal business structures are designed to access the tax provisions that Parliament intended to apply, without creating exposure to GAAR, general anti-avoidance provisions, or Section 56(2) deemed income charges. Corpus Juris Legal provides structured, defensible tax planning advice that withstands scrutiny. Our tax structuring practice covers entity selection, holding structure design, inter-group financing arrangements, profit repatriation planning, remuneration structuring for key executives, and ESOPs. For manufacturing companies, we advise on the optimal tax regime — Section 115BA/115BAA concessional rate versus the old regime with deductions — and the implications for MAT credit. For startups registered under Section 80-IAC, we manage the Startup India tax holiday application and compliance. Every major Finance Act introduces provisions that alter existing planning assumptions. Corpus Juris Legal provides an annual Finance Act impact analysis for retainer clients — identifying changes that require immediate structural adjustment, documenting positions taken in reliance on prior law, and advising on the transitional provisions that affect ongoing transactions. For group companies with complex inter-company arrangements, we review and restructure these annually in light of Section 92BA specified domestic transactions and arm's length pricing requirements.

Key Service Components

• ◆Corporate tax regime selection — Section 115BAA concessional rate vs old regime
• ◆Holding company and group structure design for tax efficiency
• ◆Inter-company financing — thin capitalisation and Section 94B compliance
• ◆Remuneration structuring — salary, perquisites, ESOP, and profit-linked pay
• ◆ESOPs — ESOP scheme design and Section 17(2) perquisite compliance
• ◆Section 80-IAC startup tax holiday application and compliance
• ◆Annual Finance Act impact analysis and structural review
• ◆MAT credit planning and carryforward management
• ◆Dividend distribution and Section 2(22)(e) deemed dividend planning
• ◆Section 56(2) anti-abuse provision analysis for related-party transactions

Our Approach

Our tax planning advice is always documented with a written opinion that identifies the statutory basis, applicable CBDT circulars, and relevant tribunal precedent — creating a defensible record if the position is challenged in assessment.

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