lr-labs

Cross-Border Tax Position Analysis

Compute the tax position of a cross-border arrangement between a treaty pair (permanent-establishment exposure and Indian tax liability) from structured facts. Returns a determinate legal position: the answer, the condition tree it stands on, the assumptions it makes (GIVEN set), the unresolved facts that would change it, the GAAR applicability gate, and the authority for each step — computed by a deterministic symbolic engine over compiled treaty law (no generative model in the path; same facts

Transfer Pricing Screen (India)

Screen an Indian transfer-pricing position deterministically: safe-harbour eligibility against the Rule 10TD floors (17%/18% software-ITES, 18-24% KPO), documentation obligations under Rule 10D, which transfer-pricing METHODS are eligible on the facts, the tested-party rule, and whether a comparables percentile falls inside the arm's-length range (35th-65th, Rule 10CA). Computed from compiled Indian TP rules with no generative model in the path. Use for questions about intra-group service fees,

Compiled Corridor Coverage

List which treaty pairs, PE families, and compiled-rule counts the LR Labs engine covers, plus the structured-fact schema. Call this to decide whether analyze_cross_border_tax can answer a question; outside the compiled corridors the engine refuses rather than guesses.

Tax Research Note Verification

Deterministically verify a piece of tax analysis (yours or anyone's): every citation is resolved against the compiled corpus, quotes and thresholds are checked against compiled law, temporal claims against validity windows — INCLUDING claims about what a named case held (E-Funds, Formula One, Morgan Stanley, Tiger Global, Progress Rail, Centrica …), checked against a string-verified holdings ledger. Write the claim as a sentence ('E-Funds held that outsourcing creates a fixed place PE') and it i

Compiled Rule Lookup

Answer a RULE-LEVEL question directly from compiled law: thresholds and day counts, WITHHOLDING TAX rates on royalty and fees for technical services (treaty and domestic), the 1961→2025 Income-tax Act section renumbering (s.195→s.393(2), s.115A→s.207, s.90→s.159, s.206AA→s.397(2)), tests and their elements, what a named case held. Ask in plain language — 'what is the India–US royalty WHT rate' (15%, not the widely-repeated 10%), 'what replaced section 195', 'is software payment royalty after Eng