International Tax & Transfer Pricing AI
The only AI platform covering DTAA treaties of 100+ countries with India, OECD & UN Model Conventions, BEPS Action Plans, and the complete Indian Transfer Pricing framework (Section 92 to 92F + Rules 10 to 10E). Six workflows purpose-built for cross-border tax research, TP opinions, notice replies, and appellate drafting.
Dual Coverage. One Platform. Every Citation Verified.
International Tax and Transfer Pricing in a single AI — DTAA treaties, OECD & UN Models, BEPS, Chapter X of the Act, and every ITAT TP bench decision cross-referenced
DTAA Database of 100+ Countries
The only platform in India with a searchable database of Double Taxation Avoidance Agreements covering 100+ jurisdictions. Article-level navigation for PE (Article 5), Business Profits (7), Royalty (12), FTS, Capital Gains, and MAP.
Complete TP Framework
Section 92 to 92F of the Income Tax Act, Rules 10A to 10E, Safe Harbour Rules, APA framework, and Country-by-Country Reporting (Section 286). Every provision linked to the governing case law.
BEPS Action Plan Tracker
All 15 BEPS Actions with India's implementation status, the MLI positions, and the interplay with existing DTAAs. Action 13 CbCR, Action 7 PE, Action 8-10 TP — ready for reference.
All ITAT TP Benches Covered
Bangalore, Delhi, Mumbai, Pune — every TP bench ruling tagged, searchable, and cross-cited. Plus APA summaries, DRP directions, and High Court / Supreme Court pronouncements on TP and cross-border tax.
Every Cross-Border Task — AI-Powered
From treaty interpretation to writ drafting — six dedicated workflows designed for international tax and transfer pricing practice
Research
Ask any INTL or TP question in plain language. The AI returns an answer grounded in case law, with ITAT / HC / SC citations, DTAA article references, and the relevant section of the Income Tax Act — every source verifiable.
Treaty Analysis
Select India and any partner jurisdiction — the AI analyses specific DTAA Articles (5, 7, 11, 12, 13, 15), compares with the OECD and UN Model Conventions, and flags the MLI modifications that apply to the chosen treaty.
TP Opinion
Describe the international transaction — the AI drafts a transfer pricing opinion with the most appropriate method (CUP, RPM, CPM, PSM, TNMM), comparability analysis per Rule 10B, benchmarking approach, and FAR analysis. Section 92C compliant.
Notice Reply
Paste a Section 92CA(3) TPO order, DRP directions, Section 148 reopening notice on cross-border income, or a Section 201 withholding notice — the AI drafts a comprehensive reply with factual, legal, and judicial defences.
Grounds of Appeal
Draft grounds of appeal before the ITAT TP benches, DRP objections under Section 144C, or CIT(A) appeals on cross-border matters. Each ground is supported by the controlling TP bench ruling and the relevant Rule 10 sub-provision.
Writ Petition
Constitutional remedies for international tax matters — jurisdictional challenges to Section 148 on DTAA-protected income, challenges to treaty-override provisions, MAP invocation support, and Article 226 drafting with precedent mapping.
From Query to Citation — Three Steps
A purpose-built RAG pipeline that reads your question, searches the right corpus, and cites every source
Ask in Plain Language
Type your question the way you'd ask a senior partner. "Is reimbursement of expenses to foreign AE subject to withholding under Section 195 if there's no income element?" — no special syntax needed.
AI Searches the Right Corpus
The engine routes the query across DTAA articles, ITAT TP bench rulings, Rule 10A to 10E commentary, OECD TPG chapters, and BEPS deliverables — returning only the passages that actually answer the question.
Answer With Every Citation
You get an answer with inline citations — case names, paragraph numbers, DTAA article, section, rule. Click any citation to read the source. Copy-paste ready for opinions and submissions.
Built for Cross-Border Tax Practice
From in-house MNC tax teams to Big-4 TP consultants to solo practitioners handling withholding opinions
International Tax Practitioners
Withholding opinions, PE analysis, DTAA characterisation, MAP and APA advisory — research in minutes, not days
MNC In-House Tax Teams
TP documentation support, CbCR compliance, intercompany opinions, and notice defence without paying Big-4 rates
TP Consultants
Method selection, comparability analyses, benchmarking studies, and appellate representation — all backed by ITAT TP bench rulings
Cross-Border Tax Lawyers
Draft grounds of appeal, writ petitions, and MAP submissions with every citation verified against the source
What No Other Platform Has
The coverage gaps INTL/TP AI fills — coverage you won't find on generic tax portals
Questions From Practitioners
The questions we hear most often from international tax and TP practitioners
Yes. Every DTAA article answer is cross-referenced against the OECD Model Commentary and, where relevant, the UN Model Commentary. The AI flags where India has taken a reservation or a position (e.g., Article 5 service PE, Article 12 FTS).
All five prescribed methods under Rule 10B — CUP, RPM, CPM, PSM, TNMM — plus the residuary "other method" under Rule 10AB. The AI recommends the most appropriate method based on the FAR analysis you describe and cites the controlling ITAT decision for that transaction type.
BEPS Actions are already embedded in Indian law — Action 13 is Section 286 (CbCR), Action 7 influenced the Significant Economic Presence (SEP) provisions, Action 8-10 aligns with the DEMPE and value-creation approach the ITAT increasingly adopts. The AI traces each BEPS Action to its Indian transposition.
Yes — the AI checks eligibility against Rules 10TA to 10TG, the thresholds for each eligible international transaction (IT/ITeS, KPO, contract R&D, manufacturing, intra-group loans, corporate guarantees), and the procedural steps under Rule 10TD. It also compares Safe Harbour margins with typical APA outcomes.
Yes. The Grounds of Appeal workflow produces numbered grounds tailored to your facts — jurisdictional grounds, method-selection grounds, comparability grounds (filters, functional dissimilarity, economic adjustments), and procedural grounds. Each is supported by the governing ITAT TP bench ruling.
Every citation is verifiable and every answer is grounded in the source corpus. As with any research tool, professional judgment is required — but the AI removes the heavy lifting of finding, reading, and cross-referencing hundreds of TP rulings and treaty provisions.
Ready to Transform Your Cross-Border Practice?
DTAA treaties of 100+ countries. 50,000+ INTL/TP cases. All 15 BEPS Actions. Six AI workflows. One platform.