RegulatorySample

Reduced effective tax rate by 8% on a cross-border pharma acquisition

How we restructured a pharma group's acquisition holding chain to optimise effective tax rate while staying fully FEMA- and treaty-compliant.

ADA Transaction Advisory12 Mar 20261 min readInternational Tax & Transfer Pricing

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Challenge. A mid-sized pharma group acquiring a target across two jurisdictions faced a high effective tax rate and FEMA reporting complexity on the holding structure.

Approach. We modelled alternative holding chains, applied the relevant treaty network, validated substance and beneficial-ownership conditions, and aligned the FEMA filings (FC-GPR/ODI) with the deal timeline.

Outcome. The implemented structure reduced the group's effective tax rate by approximately 8% on the acquired earnings stream, with all cross-border filings completed on time.

Illustrative and anonymised. No client is identified. Outcomes depend on facts and are not a guarantee of results.

M&AInternational TaxPharmaFEMA

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