Neha Rai (CA)

Base Erosion and Profit Shifting (BEPS)

• Assisted in various BEPS related India compliances such as filing MasterFile in Form 3CEAA, filing Master file notification in Form 3CEAB and filing CBCR notification in Form 3CEAC

Advisory

• Assisted in analysis of various business models for proposed international transactions and suggesting the most effective business model from a Transfer pricing perspective
• Assisted in identifying inter-company transactions; understanding Transfer pricing issues; evaluating various iterative models and suggesting optimum transfer pricing policy and solution

Assessment / Litigation

• Assisted in transfer pricing assessment proceedings for various clients engaged in media and advertising, pharmaceutical, specialty chemicals,entertainment and IT/ITes industry through preparation and filing of submissions including response to show-cause notices, undertaking legal research to substantiate various arguments and attending hearings before transfer pricing officer

• Assisted in filing objections before Dispute Resolution Panel (DRP) / appeal before Commissioner of Income Tax (Appeal)

• (CIT(A)), preparing and filing submissions, preparing factual and legal paperbook and representation before DRP/ CIT(A)

• Assisted in briefing senior counsel in relation to appeal before ITAT (Income Tax Appellate Tribunal), undertaking legal research to strengthen Appellant’s case, devising robust strategy considering factual and legal aspects; and preparation of legal and factual paperbook

• Engaged in a high-profile assignment relating to an application before the Income-tax Settlement Commission

Compliance

• Assisted in preparation and filing of Form 3CEB for various clients engaged in media and advertising, pharmaceutical, specialty chemicals and IT/ITes industry and their flipside entities

• Assisted in preparation of TP study reports; undertaking detailed FAR analysis and industry analysis; review economic and benchmarking analysis

• Engaged in preparing and filing individual income tax returns and undertaking various Direct Tax compliances

Miscellaneous

• Assisted in preparation of proposals / business development research for prospective clients

• Establish and maintain client relationship to enhance new business opportunities

• Formulation of tax opinions on high value transactions, where positions contrary to judicial precedents are sought to be taken by judicial authorities, existence of huge litigation history etc

• Introduced clients to the KPMG global network and provided one-stop-shop services by collaborating with different line of services offered by KPMG

• Attended regular meetings with the Company’s management to understand their business needs and accordingly made appropriate recommendations

• Engaged in undertaking detailed transaction review and advising on Direct Tax implications

Knowledge Management

• Assisted Senior team members / partners in preparing various slide decks for presentation at various domestic / international forums / platforms

• Assisted Senior team members / partners for various articles, news alerts and other knowledge management related work

Structured Assets Group

• Identifying initial cause of stress in large corporates, with an exposure ranging from Rs. 50 crores to 1000 crore, closely monitoring and managing funding requirements of the borrowers by resolving cashflow mismatches to prevent irregularities in payments

• Formulating strategies to strengthen the liquidity position of the company by analyzing working capital gaps and renewing

• Working capital limits or restructure debt after evaluating projections and conducting due diligence

• Implementing strategies for recovery in accounts that have slipped as NPAs through legal remedies under the Insolvency and Bankruptcy Code (IBC) and SARFAESI Act

• Closely dealing with Legal counsels, Resolution Professionals for recovery of dues from borrowers

• Attending consortium meetings and evaluating resolution plans offered by borrowers/ investors

• Coordinating with external agencies such as Advocates and valuation agencies