Indian personal tax for individuals with international connections is built on a single foundational question: where is this individual resident for tax purposes? For an Indian national living overseas, the answer to this question determines which income is taxable in India, at what rate, and whether the Foreign Tax Credit prevents double taxation. For an NRI returning to India, the question of residency status — Resident, Resident but Not Ordinarily Resident (RNOR), or Non-Resident — determines the tax treatment of overseas income and assets for up to two additional years after the return. Getting the residency question wrong is the single most expensive personal tax mistake an NRI can make.
Goldschmidt Pallonji's Personal Tax and NRI Advisory practice is built around GP's five international corridors — Australia, Singapore, UAE/GCC, Hong Kong, and the UK. For an Indian professional in Sydney, our team understands both the Indian residency analysis and the Australian tax residency rules — which use completely different criteria. For an Indian family in Dubai, our team understands both the Indian reporting obligations for overseas assets and the UAE's new corporate tax regime and its implications for individual entrepreneurs with both an Indian and a UAE business. This bilateral understanding is the difference between advice that works and advice that creates problems in the jurisdiction it did not consider.
GP's personal tax practice also serves senior executives, founders, and high-net-worth families in India — managing complex personal tax situations that arise from large ESOP exercises, founder share sales, real estate transactions, inheritance of overseas assets, and the management of family wealth across multiple generations and jurisdictions. FEMA compliance — which governs what NRIs and overseas Indians can hold, remit, and invest — is integrated into every piece of personal tax advice GP provides.
Residency planning, return-to-India structuring, foreign asset compliance, ESOP and exit tax, and family wealth management — for the Indian diaspora across all five GP corridors.
Indian tax residency analysis under Section 6 — calculating the day count for the current year and the preceding ten years, determining NRI/RNOR/Resident status, and planning the number of days in India for the coming year to achieve the desired residency outcome. For Indians in jurisdictions with their own tax residency rules — Australia, Singapore, UAE, UK — bilateral residency analysis ensuring the same income is not treated as taxable in both jurisdictions simultaneously.
Learn More →Structured return planning for NRIs relocating permanently to India — maximising the Resident but Not Ordinarily Resident (RNOR) window of two years during which overseas income from non-Indian sources is not taxable in India. Pre-return restructuring of overseas assets, super fund and pension arrangements, and foreign property to optimise the Indian tax position on return. NRE account conversion timing. FEMA compliance for repatriation of overseas funds and investment of overseas assets in India.
Learn More →Schedule FA disclosure in the Indian income tax return for all foreign assets held by Indian residents — overseas bank accounts, foreign equity investments, foreign real estate, interests in foreign trusts, ESOPs and RSUs from overseas employers, and foreign pension or superannuation accounts. Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act compliance — where past non-disclosures exist, voluntary disclosure strategy and regularisation before the Department discovers the assets through FATCA/CRS exchange of information.
Learn More →Tax planning and compliance for ESOPs and RSUs from Indian and foreign employers — the perquisite tax on exercise, the capital gains tax on sale, the holding period calculation for LTCG versus STCG, and the foreign tax credit where overseas-listed shares attract withholding in the listing jurisdiction. For NRIs returning to India who hold unvested ESOPs — planning the exercise and sale timing around the RNOR window. For founders selling shares in an acquisition — understanding the full tax consequences before signing the acquisition agreement.
Learn More →HUF formation, management, and utilisation as a tax-efficient structure for family wealth. Succession planning for Indian families with assets in multiple jurisdictions — Indian real estate, overseas investments, business interests, and family trusts. Will drafting integrated with the tax consequences of inheritance in India and the counterparty jurisdiction. For families with members in Australia, the UK, or the UAE — advising on the inheritance tax and estate duty implications in the overseas jurisdiction simultaneously with the Indian succession plan.
Learn More →FEMA compliance for NRIs — NRE and NRO account management, repatriation of funds from India, investment of NRI funds in Indian real estate and financial assets under Schedule 5 of FEMA, and conversion of resident accounts to NRO accounts on departure from India. Liberalised Remittance Scheme (LRS) compliance for Indian residents remitting funds overseas — the Rs.7 lakh TCS threshold, LRS for investment in overseas shares, and LRS for overseas property purchase. OCI cardholder investment compliance.
Learn More →A founder selling shares in their startup — through a secondary sale, an acquisition, or an IPO — faces a personal tax event that can be one of the most significant of their financial life. The LTCG rate on listed shares, the STCG rate, the LTCG rate on unlisted shares, the Section 54F exemption for reinvestment in residential property, the Angel Tax implications of shares issued below FMV in prior rounds, and the treatment of convertible notes and preference shares on exit — all of these require specific personal tax analysis. GP advises founders on the personal tax consequences of their exit before the term sheet is signed — so the structure of the exit minimises the personal tax on the same proceeds.
When an Indian-resident individual inherits assets from an overseas estate — a UK parent's property, an Australian sibling's investment portfolio, a GCC relative's business interest — the Indian tax consequences, the FEMA implications of receiving the inheritance, the reporting obligations in Schedule FA, and the estate or inheritance tax in the overseas jurisdiction all need to be addressed simultaneously. India has no estate duty — but Australia has capital gains tax on the deemed disposal at death of Australian assets, the UK has inheritance tax, and the UAE is establishing its own succession framework. GP advises the Indian beneficiary on all of these simultaneously.
For an NRI who has spent ten or fifteen years building a life and a career overseas — and who is now considering returning to India — the personal tax conversation is not about filing a return. It is about the architecture of the next phase of your financial life. What happens to your overseas super fund or pension? What happens to your overseas property? What happens to your overseas shares? What is your Indian tax status on the day you land — and how long does the RNOR window last? GP answers all of these questions from practitioners who have themselves navigated the same corridors — not from research. Call us before you book the one-way flight.
Every Indian NRI adviser understands the Indian tax position. GP additionally understands the counterparty jurisdiction's tax rules — from practitioners who have worked in Australia, Singapore, the UAE, Hong Kong, and the UK. The advice GP gives to an Australian-based NRI is built on an understanding of the ATO's rules on tax residency, super fund regulation, and capital gains — not a reading of the India-Australia DTAA from the Indian side. This bilateral understanding is the difference between advice that solves the problem and advice that creates a new problem in the jurisdiction it did not consider.
Every personal tax decision for an NRI has a FEMA dimension. The NRE account balance that becomes taxable when residency changes — FEMA. The overseas property that an NRI wishes to bring to India — FEMA. The LRS remittance that the non-resident wishes to make to India — FEMA. GP handles both the income tax and the FEMA dimensions of every NRI personal tax situation from one team — ensuring the advice is consistent and complete across both regulatory frameworks simultaneously.
The FATCA and CRS automatic exchange of information means that the Income Tax Department receives annual information about Indian residents' overseas accounts — from over 100 jurisdictions. Indian residents with overseas assets that have not been reported in Schedule FA are increasingly likely to receive notices from the Department. GP advises on voluntary regularisation before the Department's notice arrives — identifying all overseas assets, preparing the Schedule FA disclosure, and managing the voluntary disclosure process that minimises the penalty and prosecution exposure under the Black Money Act.
Complete confidentiality maintained. These matters illustrate the nature of our personal tax and NRI practice.
Advised a Sydney-based Indian senior executive on the tax planning for a permanent return to India after 18 years in Australia. GP's planning maximised the RNOR window by structuring the return date and the day count precisely. The AUD 1.4M superannuation fund balance was restructured — with GP advising on both the Australian super regulations and the Indian DTAA position — to ensure that income accruing within the super fund during the RNOR period was not taxable in India. Pre-return restructuring of Australian property and share portfolio completed before the return date. The RNOR period was fully utilised, protecting overseas income from Indian taxation for the maximum two-year period.
Advised an Indian-resident family on the voluntary regularisation of overseas assets — UAE property, UAE bank accounts, and UK equity investments — that had not been disclosed in Schedule FA for six years. GP assessed the family's Indian residency status for each relevant year, determined the income earned on the assets that was taxable in India, and managed the voluntary disclosure process. The regularisation was completed before the relevant year's FATCA/CRS exchange could bring the assets to the Department's attention. The voluntary disclosure approach — with full payment of taxes and interest — avoided the 120% penalty and prosecution exposure under the Black Money Act.
Advised a Mumbai-based startup founder on the personal tax planning for a Rs.22 crore exit through a secondary sale to a PE fund. GP analysed the founder's shares — some held as promoter shares since incorporation, others received as ESOP exercises at different dates — and calculated the holding period, cost of acquisition, and LTCG/STCG characterisation for each lot. The ESOP exercise timing was restructured (within permissible terms) to maximise the proportion qualifying for long-term treatment. Section 54F exemption was claimed for reinvestment of the LTCG proceeds in residential property. The effective tax rate on the Rs.22 crore exit was reduced from the projected 30% to under 12%.
The practice is led by a CA-qualified personal tax specialist with NRI and cross-border wealth management experience, supported by corridor-specific expertise for the Indian diaspora in Australia, Singapore, the GCC, Hong Kong, and the UK. Every NRI client is assigned a primary adviser and a corridor specialist — the primary adviser manages the Indian side, the corridor specialist manages the bilateral analysis for the client's home jurisdiction.
The practice coordinates closely with GP's Family Law practice for clients whose personal tax planning intersects with matrimonial property, and with our Inheritance & Succession practice for clients managing cross-border estate planning.
Residency calculation, the RNOR window, super fund and pension arrangements, overseas property, Schedule FA, NRE account conversion — everything an NRI needs to plan before the return. Specific chapters for Australia, Singapore, UAE, and UK corridors.
Read Guide →A plain-language guide to the Schedule FA foreign asset disclosure — what must be reported, how to value each asset class, and how to regularise past non-disclosures before the Department's CRS data identifies them.
Read Bulletin →Whether you are planning a return to India, managing overseas assets as an Indian resident, dealing with a FATCA notice, planning an ESOP exercise, or structuring family succession — our CA and lawyer team responds within 24 hours with bilateral advice from practitioners who have worked in your jurisdiction.
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