PGM Legal is a boutique law practice advising on international tax, transfer pricing, GST, customs, exchange controls, tax controversy, transactions, restructuring, cross-border employment, and Japan–India corridor matters — with original research-led insight into how tax authorities regulate in practice.
PGM Legal advises on international tax, transfer pricing, GST, customs, exchange controls, tax offences, transactions, restructuring, investment, and cross-border corporate and employment law. The practice is distinguished by original academic research into tax administration, nineteen years of corporate leadership, and working fluency across three jurisdictions and three languages — offering clients not only what the law provides, but how the system that enforces it actually works.
Our practice is grounded in original, funded academic research into how tax authorities regulate in practice. The “bounded co-regulation” framework, developed through longitudinal study of Irish tax administration, informs every advisory engagement — providing clients with insight no purely practice-based firm can replicate.
With an enrolled advocate’s practice in Delhi and a research affiliation at UCD Sutherland School of Law in Dublin, PGM Legal operates at the intersection of Indian, Irish, and EU tax and regulatory systems. Clients working across these jurisdictions receive seamless advice from a single counsel.
Business-level Japanese (JLPT N2), combined with direct experience inside Japanese corporate environments in Tokyo and Haryana, means PGM Legal can advise Japanese businesses in India — and Indian businesses engaging Japan — directly in the language of the client, without intermediation.
Eleven years of senior HR leadership at Maruti Suzuki India — one of India’s largest automotive manufacturers — provides PGM Legal with a level of workforce compliance, employment law, and large-enterprise operational insight that most tax boutiques simply cannot offer.
Sixteen areas of concentrated expertise across tax, regulatory, corporate, and employment law — spanning policy, disputes, and transaction advisory.
Treaty interpretation, cross-border structuring, BEPS, MLI, and tax policy.
Documentation, benchmarking, APA, MAP, and dispute resolution.
Tariff classification, valuation, anti-dumping, export incentives.
Compliance, classification, ITC, e-invoicing, cross-border supply.
FEMA, RBI regulations, ECB, outward/inward remittance.
Tax prosecution, penalties, investigations, defence strategy.
M&A tax, due diligence, restructuring, post-deal compliance.
IBC proceedings, CIRP, financial distress, creditor rights.
FDI, DPIIT, bilateral investment treaties, regulatory approvals.
Co-regulation, consultative mechanisms, authority engagement.
Representation before authorities, tribunals, appellate forums, ADR.
Labour law, expatriate tax, social security, workforce structuring.
Treaty, regulatory, and commercial advisory conducted in Japanese.
Contracts, governance, vendor agreements, regulatory compliance.
OECD Pillar One/Two, digital services tax, BEPS 2.0, GloBE rules.
HNI taxation, succession planning, cross-border estate structuring.
Comprehensive advisory across the full spectrum of tax, regulatory, and corporate law.
PGM Legal provides strategic advisory on cross-border tax structuring, double taxation treaty interpretation, and the interaction between domestic and international tax rules. We meticulously analyse bilateral and multilateral tax treaties to ensure clients understand their rights and obligations while leveraging these agreements to optimise tax positions across jurisdictions.
Our work encompasses comprehensive treaty planning, assessment of tax treaty implications on cross-border transactions, and strategic advice on minimising tax liabilities and mitigating risks associated with international operations. We advise on permanent establishment exposure, withholding tax optimisation, treaty shopping risk, and the application of the MLI.
We possess deep expertise in transfer pricing, meticulously analysing inter-company transactions to ensure compliance with local and international regulations. Our team crafts tailored transfer pricing strategies that mitigate risks and enhance the overall financial structure of businesses.
Through rigorous benchmarking studies, detailed documentation, and economic analysis, we provide clients with insights that foster transparency and defensibility in pricing arrangements. Our practice covers advance pricing agreements (APA), mutual agreement procedures (MAP), competent authority negotiations, and transfer pricing dispute resolution before appellate forums.
In the evolving landscape of customs and international trade, PGM Legal serves as a cornerstone of compliance and strategic advice. We offer guidance on tariff classification, customs valuation, import/export regulations, anti-dumping and safeguard duties, export incentives, and trade agreements — ensuring alignment with domestic and international trade laws.
We advocate for clients’ interests during customs disputes and facilitate smoother trade operations, empowering businesses to navigate regulatory frameworks while optimising duty positions and leveraging preferential trade arrangements.
Navigating the complexities of GST requires acute insight. We offer comprehensive advisory services encompassing compliance planning, classification analysis, input tax credit optimisation, inter-state and intra-state supply structuring, e-invoicing, reverse charge mechanism, and dispute resolution and litigation strategies tailored to each client’s circumstances.
Our proactive approach in deciphering evolving GST regulations enables businesses to optimise tax positions, minimise liabilities, and streamline operations in both domestic and international trade contexts.
We assist businesses in understanding and complying with foreign exchange regulations, facilitating smooth cross-border transactions and investments. Our team delivers clear and practical solutions ensuring clients optimise financial operations while remaining compliant with the evolving landscape of exchange controls under FEMA and RBI regulations.
Our advisory covers ECB structuring, outward and inward remittance, LRS compliance, overseas direct investment, and the regulatory interface between exchange controls, tax, and corporate law.
Our proficiency in handling tax-related offences underscores our commitment to safeguarding clients’ interests. We navigate the intricate landscape of tax prosecution trials, offering robust defence strategies in cases of non-compliance, audits, investigations, search and seizure proceedings, and penalty proceedings.
We ensure clients are represented with diligence through every stage of prosecution — from show-cause notices to trial and appellate proceedings — seeking favourable resolutions while upholding legal and ethical standards.
In the realm of transaction advisory, our expertise in mergers and acquisitions integrates with our commitment to unparalleled legal guidance. Our comprehensive services encompass tax due diligence, strategic acquisition planning, global structuring, and advisory support across the full transaction lifecycle.
We specialise in the tax and regulatory aspects of cross-border and domestic M&A, joint ventures, demergers, slump sales, share purchases, and asset acquisitions. We also advise on post-transaction integration, compliance, and restructuring to ensure tax-efficient outcomes.
Our insolvency and bankruptcy practice equips clients with the support needed to navigate the complexities of financial distress under the Insolvency and Bankruptcy Code (IBC). We combine legal insight with strategic foresight, assisting creditors and debtors alike in achieving optimal outcomes.
Whether through corporate insolvency resolution processes (CIRP), restructuring, liquidation, or cross-border insolvency matters, we provide comprehensive solutions that prioritise stakeholder interests and uphold the integrity of the insolvency process.
At the intersection of investment and legal frameworks, we provide advisory services that empower clients to maximise investment potential. Our expertise spans foreign direct investment (FDI) policy, DPIIT compliance, bilateral investment treaty advisory, portfolio investments, venture capital, and private equity regulatory approvals.
We work closely with clients to facilitate inbound and outbound investments, navigate sector-specific caps and conditions, and structure investments to comply with Indian and international regulatory requirements.
This practice area is PGM Legal’s distinctive contribution. Grounded in original academic research on how tax authorities regulate — specifically the “bounded co-regulation” framework developed through longitudinal study of the Irish Tax Administration Liaison Committee (TALC) — we advise on how to engage effectively with consultative and co-regulatory processes.
We assist clients in understanding where and how professional engagement with a tax authority can be most effective, drawing on empirical evidence rather than assumption. For policymakers, we offer diagnostic tools for evaluating whether consultative mechanisms are functioning as intended.
We represent clients across all phases of tax controversy — from initial assessments and show-cause notices through administrative appeals, appellate tribunals, High Courts, and advisory on proceedings before the Supreme Court. Our practice encompasses direct tax, indirect tax, and transfer pricing disputes.
We also advise on alternate dispute resolution mechanisms including advance rulings, advance pricing agreements, mutual agreement procedures, and settlement commission proceedings. Our approach combines strategic foresight with rigorous technical analysis to achieve optimal outcomes at every stage.
Drawing on eleven years managing large-scale workforce operations at Maruti Suzuki India, we advise on labour and employment law for enterprises of all sizes. Our practice covers employment contracts, industrial disputes, social security compliance, expatriate taxation, cross-border employment structuring, and workforce regulatory compliance.
We also advise on secondment arrangements, social security agreements between India and other countries, tax equalisation policies, and the employment law aspects of M&A transactions including TUPE-equivalent obligations and workforce integration.
PGM Legal offers a rare combination in the Indian legal market: direct, business-level Japanese language capability (JLPT N2) combined with hands-on experience inside Japanese corporate environments in Tokyo (Canon Kosugi KK) and Haryana (Denso). We advise Japanese businesses operating in India and Indian businesses engaging Japan on treaty, regulatory, and commercial matters — directly in Japanese where required.
Our advisory covers India–Japan DTAA structuring, permanent establishment risk, transfer pricing for Japanese parent–Indian subsidiary arrangements, joint venture structuring, regulatory approvals, and employment law for Japanese expatriates in India.
We advise on commercial contracts, vendor and supply-chain agreements, corporate governance, regulatory compliance, and the full range of corporate advisory services for businesses operating across jurisdictions. Our work includes drafting and negotiating commercial agreements, advising on Companies Act compliance, board advisory, and regulatory filings.
As the international tax landscape evolves through the OECD/G20 Inclusive Framework, PGM Legal advises on the impact of Pillar One (reallocation of taxing rights) and Pillar Two (Global Minimum Tax / GloBE rules) on multinational businesses. We also advise on digital services taxes, equalisation levies, and the broader policy landscape surrounding taxation of the digital economy.
Our research-led approach means clients receive advisory that integrates current policy developments with an understanding of how these rules will be administered in practice across jurisdictions.
We advise high-net-worth individuals, family businesses, and promoter groups on succession planning, cross-border estate structuring, wealth preservation, and the tax implications of global mobility. Our advisory covers residential status planning, disclosure obligations, overseas asset reporting, and the interaction between Indian tax law and foreign tax regimes affecting private wealth.
An original analytical framework developed through funded research at UCD Sutherland School of Law, identifying three structurally distinct modes of co-regulation in tax administration.
Co-regulation shaped and limited by the substantive policy discretion a tax authority retains — the boundaries set by legislative mandate and executive choice.
Co-regulation shaped by the formal consultative and procedural mechanisms through which stakeholders engage with the authority — committee structures, submissions, feedback loops.
Co-regulation shaped by the institutional architecture connecting the authority to government and the legislature — organisational design, reporting lines, and accountability.
Cross-sector advisory informed by direct industry experience and research.
Informed by eleven years at Maruti Suzuki India and experience with Denso and Canon.
DST, equalisation levy, Pillar One/Two compliance, and IP-related tax structuring.
FEMA compliance, ECB structuring, cross-border capital flows, and investment fund taxation.
GST on immovable property, joint development agreements, RERA compliance, and project structuring.
Direct Japanese-language advisory for Japanese corporates operating in India and the Asia-Pacific.
Partnership taxation, cross-border secondment, employment structuring, and regulatory compliance.
Supply chain tax planning, customs optimisation, and indirect tax compliance for consumer businesses.
Project structuring, tax incentives, green tax, and regulatory compliance for infrastructure projects.
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Parulh G Mahajan is an Advocate enrolled with the Bar Council of Delhi and the founder of PGM Legal. She brings nineteen years of professional experience to her legal practice, combining a rare breadth of expertise across international tax, regulatory policy, corporate law, and large-enterprise workforce management.
Her career includes eleven years in senior HR leadership at Maruti Suzuki India Ltd, where she managed large-scale workforce operations for one of India’s largest automotive manufacturers. Earlier, she worked within Japanese corporate environments at Canon Kosugi Kabushiki Kaisha in Tokyo and Denso in Haryana, building direct fluency in Japanese business practice, language, and regulatory culture.
She is currently a Research Assistant at UCD Sutherland School of Law, working under Professor Emer Hunt on a Fitzpatrick Foundation-funded project examining co-regulatory mechanisms in Irish tax administration. This research — and the original “bounded co-regulation” framework it produced — underpins PGM Legal’s advisory work on how tax authorities function in practice, not only what the law formally provides.
She holds an MSc in International Law and Business from University College Dublin (2:1), an LLB (2:1), an MBA (First Class), and CIPD Level 7 equivalent qualifications. She is a Director of Crosby Project Private Limited, a volunteer with St John of God and the Ireland India Business Association, and is based between Dublin and Delhi.
Representative engagements across practice areas. Details are anonymised or generalised in compliance with professional obligations.
Research, commentary, and analysis on tax administration, international tax, transfer pricing, and cross-border regulatory developments.
Identifying policy-bounded, process-bounded, and structural-bounded co-regulation through longitudinal empirical analysis of the TALC, 2012–2025.
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Read more →Research affiliation at UCD Sutherland School of Law. Advisory on Irish and EU-facing cross-border tax, regulatory, and employment matters. Direct engagement with Revenue Commissioners and TALC consultative processes.
Enrolled Advocate, Bar Council of Delhi. Full representation before Indian tax and regulatory authorities, ITAT, and appellate forums. Advisory across Delhi NCR and pan-India, with dedicated Japan corridor capability.
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