Dhanalakshmi Pillai Perumal

At OMRAN as a legal advisor, reviewing and advising on its FIDIC based construction contracts, preparing summary of risks and liabilities under the construction contracts for the management, managing Omran’s real estate portfolio, advising on real estate corporate structures, drafting and reviewing Hotel Management Agreements, advising on PSQ Waterfront Integrated Tourism Complex (“ITC”) project structures, drafting related contracts such as concession agreement and development agreement with Ministry of Tourism, due diligence exercises, drafting Usufruct agreements, company formations, share transfers and advising on board and general meetings.

Role and responsibilties: Advise on taxation of branches, projects, consultancy services by foreign companies, withholding tax, double tax treaty interpretation, head office allocation, allowable expenses, availing foreign tax credit for Omani companies on the foreign tax paid abroad, etc.

Incorporation of LLC and branches of Foreign Companies, Joint Ventures, Acquisition of shares, transfer of shares, contractual due diligence, drafting and perusal of complicated contracts.

Role and responsibilities: In Oman tax law - Advise on tax holidays, investment in travel and tourism industry, taxation of branches, taxation when employees work onshore without base, tax audit and tax filing for management companies, source taxation on profits earned through offshore drilling ships, withholding tax for royalties, management fees, handling litigations relating to profit realization on share transfer, tax accounting on disallowance of expenses and amortizations/ depreciations, thin capitalisation, related party transactions.
In International taxation - Application of double tax treaties, permanent establishment rules, avoidance of withholding tax under treaties, exemption by home country, trade between India and Oman, coordinate on tax planning structures, etc.
• Worked as Deputy Manager with Deloitte. in Bangalore, India (March 2009 till May 2009)
Role and responsibilities: Group restructuring involving US companies, advising on tax efficient cash repatriations and other international tax planning on inbound and outbound investments for clients in IT/ ITES Sector.

In Dutch tax law - Advise on the participation exemption, thin capitalisation, inter-company transactions, tax base erosion, tax loss carry over, tax provision, group taxation, review of book to tax difference (permanent & temporary), calculation of deferred tax, calculation of effective tax rate, filing objection on tax assessments.
In International taxation - Advice on tax treaty interpretation, withholding tax rules, International tax planning opportunities through Netherlands for clients in mining Industries, advice on European Community tax directives.