
Editorial September 2026
Dear Readers,
During the month of August 2026 Mr. Raghu Marwah, CEO visited Los Angeles, USA and met
CPAs, Lawyers and businessmen focusing on cross border transactions. The USA market
remains very robust.
On the Direct Tax front, the Hon’ble High Court of Delhi in the case of Ernst & Young USA
LLP held that secondment payments amounted to taxable Fee for Technical Service (FTS),
reinforcing a stricter approach to determine the ‘real employer’ in cross-border secondment
arrangements, emphasizing substance over form. Secondment arrangements between
MNCs, GCCs and their Indian affiliates is likely to be impacted by this judgement and
warrant re-examination.
On the Assurance front, the RBI has issued the Reserve Bank of India (Non Banking Financial
Companies- Statutory Audit) Directions 2026. Notable changes include, enhanced role of
Boards and Audit Committees in overseeing audit function, mandatory joint audit for large
NBFCs of asset size above INR 15,000 crore, enhanced branch audit coverage, rigorous
eligibility criterion for audit firms and auditor rotation after 3 years.
RNM Capital Trust, an Alternative Investment Fund (AIF) category 3 based out of Gift City
catering to Non Residents continued its good performance in the month of August, inspite
of wider markets remaining range bound.
RNM Tower, our green certified commercial leasing building in Mohan Co-operative, New
Delhi during the month continued to attract a lot of leasing interest. The negotiations with
various players to ensure the ideal tenant mix continues. We are very thankful to the real
estate broker community for supporting our initiatives.
We would like to take this opportunity of wishing all our readers Happy Janamashami on 4
September. On this day we celebrate the birth of Lord Krishna and the triumph of truth over
falsehoods.
Raghu Marwah
Chartered Accountant | International Taxation, FEMA & Corporate Advisory
Raghu Marwah is a Chartered Accountant, leading the firm's Consultancy Services and International Taxation practice. He advises Indian and international businesses on FEMA and RBI regulations, cross-border taxation, transfer pricing, India-entry strategies and overseas expansion. His professional experience also includes audit, tax compliance, M&A transactions across India and International Markets.