Bipluv Jhingan

Bipluv has 10 years of experience advising on complex tax matters across industries.

He specialises in direct & international tax advisory, working with multinational corporations, financial institutions, digital asset businesses, and high-net-worth individuals on issues relating to treaty interpretation, permanent establishment risk, and global tax efficiency. His practice spans cross-border strategic transaction structuring, in/outbound investment advisory, capital markets taxation, digital asset taxation, private client matters, as well as tax controversy strategies.

He advises clients across a broad range of industries, including Automotive, Education, Financial Services, Fintech, Hospitality, Infrastructure, Insurance, ITeS, Media & Entertainment, Pharmaceuticals, Private Equity, Real Estate, Telecommunications, Cryptocurrency, and Manufacturing, among others.

Bipluv is an active thought leader in the tax domain, having authored numerous articles and blogs on direct and internaltional tax matters published in leading newspapers, reputed journals, and prominent tax platforms.

Relevant Experience:

International Tax Advisory: Advising on a broad range of international tax matters, including assessment of permanent establishment risks across diverse business models, including secondments, franchise structures, and digital platforms, alongside income characterization under applicable tax treaties, with a focus on optimizing cross‑border tax outcomes and ensuring robust treaty compliance.
Inbound Structuring & Cross-Border Expansion: Evaluating and advising on inbound structuring strategies for the tax-efficient establishment of global capability centres, foreign branch offices, and GIFT City operations, as well as diverse cross‑border ventures (including fintech and crypto), supported by analysis of funding structures, repatriation strategies, and exit options.
Corporate Tax Structuring & Strategic Transactions: Conceptualizing and evaluating on tax‑efficient structuring for acquisitions, divestments, pre‑IPO consolidations, and corporate reorganisations (including mergers, demergers, re‑domiciliation, and share swaps), while ensuring regulatory alignment and maximizing stakeholder value.
Documentation & Drafting: Advising on and preparing tax-related documentation across commercial, transactional, and capital markets contexts, including:
Commercial Documentation: Reviewing service agreements, employee incentive plans, licensing, and franchise arrangements to identify structural refinements that align commercial arrangements with tax laws, mitigate permanent establishment risks, prevent unintended tax outcomes, and ensure compliance with withholding obligations and income characterisation principles.
Transactional Documentation: Drafting and negotiating tax clauses in transaction documents, including share purchase, business transfer, and asset transfer agreements, covering indemnities, representations and warranties, withholding obligations, and other tax covenants.
Capital Markets Documentation: Assisting with the drafting and review of tax-related sections in private placement memoranda (PPMs), offering circulars for bonds, draft red herring prospectuses (DRHPs), and red herring prospectuses (RHPs), covering domestic and international tax implications, investor tax disclosures, and withholding tax considerations.
Controversy & Dispute Resolution: Experience in preparing petitions, briefs, and submissions in tax litigation matters, supporting senior counsel on complex factual and legal issues, and advising clients on dispute strategy, risk mitigation, and resolution.