S. KRISHNAN


Krishnan is an international tax professional with significant on-ground practical experience of globalizing a company’s operations. He has managed the entire gamut of planning, compliance, tax audits and litigation in international income-tax and transaction tax; due diligence and contract structuring as well as risk mitigation. He is assisting companies on international tax structuring and performing the role of a virtual international tax manager providing ‘tax health check-up’ and compliance oversight of international tax, employee mobility and transaction taxes. He is based out of Bangalore, India.

He was earlier Vice President and Group Head – International Taxation at Infosys Limited (formerly called Infosys Technologies Limited). Over a period of 15 years at Infosys, he set up a centralized international tax department in Bangalore to manage tax compliance in over 30 countries across North America, Europe, Asia Pacific, Africa and Russia. He was responsible for filing corporate income tax returns in these countries and paying income taxes within the due dates. He has established appropriate tax filing methods supported by Transfer Pricing studies. He has personally managed income tax audits across USA, UK, Belgium, Canada, Germany, France, Netherlands, Japan, Singapore, Australia, etc. very efficiently. He settled a corporate tax audit in Japan through a Mutual Agreement Procedure involving the Competent Tax Authorities of India and Japan. During this process, he worked closely with the Government of India in reducing the withholding tax rate on Royalties and Fees for Technical Services as per the Double Tax Avoidance Agreement between India and Japan from 20% to 10%.

Krishnan has significant knowledge and experience in global transaction tax compliance regime such as Sales Tax, VAT, Goods and Services Tax (GST), Consumption Tax and such else. He has set up processes for charging appropriate transaction taxes on invoices.

Krishnan has experience in the complete chain of employee mobility activities such as obtaining work and residence permits for employees deputed to work in foreign countries, drafting deputation letters, implementing tax efficient compensation policies for such employees, obtaining social security exemptions and managing payroll compliance. Krishnan has leveraged employee tax benefits such as the Dispensation Scheme in the UK, LAFHA in Australia, 30% ruling in the Netherlands, Special Expat benefits, etc., while designing the compensation structure for employees deputed to foreign countries. He has also addressed the corporate tax consequences of employee mobility. He has significant experience in managing employee deputation and secondment arrangements.

Krishnan has published an elaborate Discussion Paper on drafting Foreign Tax Credit Rules in India and articles on the onerous reporting requirements in the U.S. on its citizens and green card holders residing outside the U.S.

Krishnan holds a bachelor’s degree in commerce from Bangalore University. He is an Associate Member of the Institute of Chartered Accountants of India and the Institute of Cost Accountants of India.