Aditya S Raman Email & Phone Number

Bengaluru, Ka, In

Bengaluru, Karnataka, India

Mumbai, Maharashtra, India

Managing the tax function at PDS Group, overseeing tax functions across geographies.Spearheaded multiple Group level initiatives including tax transformation, revamping the tax and transfer pricing structures/ policies, monitor and take necessary measures to comply with BEPS 2.0 (global minimum tax) proposed to be introduced, re-evaluate existing tax structures for tax efficiency, among others. Also, was actively leading the Group in tax assessments across the globe.

Mumbai, Maharashtra, India

Leading the Group Tax Function at PDS Group, reporting to the Group CFO - India direct tax & GST: Tax compliance for India Group entities – ITR, TDS returns, Advance tax, SFT, WHT, GST returns, GST annual returns, SFT returns etc.- Global Tax management: I oversee direct tax compliances, litigation and advise on corporate/ transfer pricing/ international tax issues for over 100+ Group entities, across 22 jurisdictions [primarily focusing on India, Hong Kong, Mauritius, UAE, Bangladesh, UK, USA, China among others] - Group transfer pricing & International taxation: Master File, CBCR, TP documentation for Group entities, transfer pricing policy making, BEPS 2.0 (Global minimum tax) implementation - Group Tax Policy: Over the past couple of years, I have effectively developed Group tax & transfer pricing policies to optimize tax flows within the Group - Tax strategy/ transformation: Partner with CFOs worldwide to structure/ restructure transactions to ensure tax optimization/ efficiency - Tax Litigation: Review, strategize and develop written responses for filing with tax authorities worldwide, against queries/ notices/ during assessments, to effectively mitigate tax risks/ exposures - Stakeholder Management: Effectively connect and work with multiple stakeholders on a daily basis - Group CEO/ CFO, CFOs and Financial Controllers of Group companies across the globe, Auditors, Tax Consultants, Finance/ Legal teams, etc.

Bengaluru, Karnataka, India

International taxation and transaction services/ M&A Tax - Buy-side/ sell-side tax due diligences: Undertook comprehensive tax due diligences of companies’ financial statements, annual reports, statutory filings and other deal documents to identify potential gaps/ tax & regulatory exposures and effectively addressing these issues - Transaction structuring: Involved in structuring transactions of mammoth sizes for optimizing tax flows, including review of holding structures, cash repatriation strategies etc. - Transaction implementation: Preparation/ review of transaction documents post finalising structures – Term sheets, Shareholder Agreements, Share Purchase Agreements, Inter-company agreements etc. - Stakeholder Management: Effectively coordinating with multiple stakeholders involved in transactions, including Investors, Clients, Target Companies, Lawyers, Managements Consultants, etc.

Bengaluru, Karnataka, India

Transfer Pricing and International tax services team- Dispute resolution: Unilateral & Bilateral Advance Pricing Agreements (APA), Safe Harbours and Mutual Agreement Procedures (MAP) - led and actively involved in commercial negotiations with the US IRS in finalizing 3 bilateral APAs and a MAP (Combined value of transfer pricing adjustments >INR 750cr) - Compliances: Managed a portfolio of global clientele across multiple sectors in undertaking day-to-day tax and transfer pricing compliances (Master File, Local File, CBCr related compliances, Accountant certifications. etc.)- Domestic litigation: Representation before Income-tax authorities (AO, TPO, Commissioners and Dispute Resolution Panels). Managing representation before Income-tax Appellate Tribunal, Karnataka High Court, the Supreme Court- International taxation: Permanent Establishment risk analysis, POEM risk analysis, Reviewing Double Taxation Avoidance Agreements, model conventions/ commentaries etc.

Bengaluru, Karnataka, India

Transfer Pricing and International tax services team - Transfer Pricing documentation: Built robust transfer pricing documentation for multiple clients from scratch - including developing functional/ risk profile of the companies involved in the transactions and undertaking economic analysis of transactions to arrive at comparable benchmarks, justifying inter-company transfer pricing policies - Transfer Pricing advisory: Global transfer pricing planning and price setting (including validating existing policies), policy making and implementation (drafting/ review inter-company agreements, forecasts etc.) - Domestic tax & transfer pricing litigation: Independently represented/ successfully defended multiple clients' transfer pricing policies/ issues before the Indian tax authorities - Stakeholder management: Seamless liaising between multiple stakeholders - Clients, Partners/ Managers, Lawyers, Department Representatives, etc.

Bengaluru Area, India

Transfer Pricing and International tax services team - Transfer Pricing documentation: Played instrumental roles in developing/ revamping transfer pricing documentation for multiple clients, across sectors - Domestic tax & transfer pricing litigation: Assisting clients develop submissions and material for defending Group's transfer pricing policies - Transfer Pricing Benchmarking: Extensively experience working on benchmarking exercises to arrive market prices/ "Arm's length prices" for the purposes of domestic/ international transfer pricing (local laws/ OECD)

Tax Law/Taxation

Finance, General

Bachelor Of Commerce - Bcom, Accounting And Finance