// ---------- DATA ----------

const EXPERTISE_LIST = [
  {
    slug: 'transfer-pricing',
    title: 'Transfer Pricing',
    short: 'Defensible inter-company pricing across jurisdictions, supported by economic analysis and contemporaneous documentation.',
    capabilities: [
      'Global and local transfer pricing documentation',
      'Benchmarking studies and economic analysis',
      'Inter-company agreements and policy design',
      'APA strategy and competent authority proceedings',
      'Country-by-Country reporting and Master File',
      'Litigation support and DRP / ITAT representation',
    ],
    implications: [
      'Permanent establishment exposure on inter-company arrangements',
      'BEPS-aligned positions for distribution, services and IP flows',
      'Pillar Two and operational TP intersection',
    ],
    summary: 'Transfer pricing is treated as a strategic planning function rather than a year-end documentation exercise. We work with finance, tax and operating teams to design pricing that is commercially coherent, contemporaneously documented and defensible under Indian and international examination.',
  },
  {
    slug: 'international-tax',
    title: 'International Tax',
    short: 'Treaty interpretation, structuring and dispute strategy across inbound and outbound positions.',
    capabilities: [
      'Inbound and outbound investment structuring',
      'Tax treaty analysis and beneficial ownership',
      'Permanent establishment and attribution',
      'Withholding strategy on cross-border payments',
      'BEPS, Pillar Two and equalisation levy positioning',
      'Holding company and IP migration analysis',
    ],
    implications: [
      'Treaty access under multilateral instrument',
      'Substance and economic-employer considerations',
      'Source-rule conflict and credit relief planning',
    ],
    summary: 'International tax advisory grounded in the substance of cross-border arrangements — not template structures. Engagements range from holding-jurisdiction selection and IP migration to attribution analysis on Indian operations of foreign principals.',
  },
  {
    slug: 'fema-cross-border',
    title: 'FEMA & Cross-Border Advisory',
    short: 'Capital, current and overseas investment matters under India’s exchange control regime.',
    capabilities: [
      'Inbound FDI and downstream investment review',
      'ODI, financial commitments and overseas structures',
      'Liaison, branch and project office strategy',
      'External commercial borrowings and trade credits',
      'LRS, NRI and resident-non-resident transitions',
      'FEMA compounding and authorised dealer interface',
    ],
    implications: [
      'Sector-cap and pricing-guideline compliance',
      'Round-tripping and overseas investment optics',
      'Exit and repatriation pathways',
    ],
    summary: 'FEMA is read as a regulatory architecture, not a checklist. We advise on the structuring, reporting and authorised-dealer dimensions of cross-border capital movement, downstream investment and exit, with an emphasis on positions that are commercially executable.',
  },
  {
    slug: 'gst-advisory',
    title: 'GST Advisory',
    short: 'Indirect tax positioning for cross-border supply chains, digital services and complex sectors.',
    capabilities: [
      'Place-of-supply and intermediary analysis',
      'Cross-border services, OIDAR and exports',
      'Input tax credit strategy and refund pathways',
      'GST on digital, SaaS and platform models',
      'Audit, scrutiny and adjudication representation',
      'Sector advisory: IT, e-commerce, real estate, financial services',
    ],
    implications: [
      'Intermediary mis-classification on offshore services',
      'Reverse-charge exposure on imported services',
      'Refund denial on zero-rated supplies',
    ],
    summary: 'Indirect tax is increasingly cross-border. We advise on positions where the place-of-supply, intermediary and export rules interact — typically in software, platform and outsourced-service businesses — and represent clients through scrutiny and appellate stages.',
  },
  {
    slug: 'audit-assurance',
    title: 'Audit & Assurance',
    short: 'Statutory, internal and group reporting audits with a controls-led, judgement-aware approach.',
    capabilities: [
      'Statutory audit under Companies Act and IFRS',
      'Group reporting packs for foreign parents',
      'Tax audit and ICDS positions',
      'Internal financial controls and SOX-aligned testing',
      'Limited reviews and agreed-upon procedures',
      'Special-purpose and regulatory audits',
    ],
    implications: [
      'Group reporting alignment with parent GAAP',
      'Auditor independence and rotation strategy',
      'Disclosure on related-party and material judgments',
    ],
    summary: 'Audit engagements are designed around the judgement areas that matter — revenue recognition in subscription and services models, expected credit loss, related-party disclosure, and group reporting alignment with foreign parent GAAP.',
  },
  {
    slug: 'cfo-strategic-advisory',
    title: 'CFO & Strategic Advisory',
    short: 'Outsourced financial leadership for growth-stage and globally structured businesses.',
    capabilities: [
      'Outsourced and fractional CFO engagements',
      'Board-level reporting and finance operating model',
      'Financial planning, FP&A and unit economics',
      'Group structuring and inter-company architecture',
      'Capital allocation, treasury and FX policy',
      'Pre-transaction readiness and data hygiene',
    ],
    implications: [
      'Investor-ready financial information stack',
      'Inter-company architecture readable to acquirers',
      'Forecast credibility under board scrutiny',
    ],
    summary: 'A CFO function for businesses that need institutional-grade financial discipline without a full senior hire. Engagements typically combine board-level reporting, group structuring, capital allocation and pre-transaction readiness.',
  },
  {
    slug: 'transaction-support',
    title: 'Transaction Support',
    short: 'Buy-side and sell-side diligence, structuring and execution-phase advisory.',
    capabilities: [
      'Financial and tax due diligence',
      'Sell-side vendor diligence and data preparation',
      'Deal structuring and SPA tax / accounting positions',
      'Working capital and locked-box mechanics',
      'Carve-out and integration support',
      'Post-close true-up and dispute support',
    ],
    implications: [
      'Tax leakage in cross-border share and asset deals',
      'Indemnity and escrow alignment with diligence findings',
      'Post-close working-capital and earn-out disputes',
    ],
    summary: 'Transactions are advised end-to-end: from early diligence through SPA negotiation to post-close true-up. Particular focus on cross-border deals where Indian regulatory and tax considerations meaningfully shape structure.',
  },
  {
    slug: 'hni-uhni-advisory',
    title: 'HNI / UHNI Advisory',
    short: 'Personal tax, residency and cross-border wealth structuring for individuals and promoters.',
    capabilities: [
      'Residency planning and exit-tax positioning',
      'Foreign asset reporting and disclosure regimes',
      'LRS, ESOPs, RSUs and cross-border compensation',
      'Inbound migration and returning Indian residents',
      'Estate, gift and intergenerational structures',
      'Trust, foundation and offshore vehicle review',
    ],
    implications: [
      'Black Money Act and undisclosed-asset exposure',
      'Treaty residency and tie-breaker positioning',
      'Reporting obligations on foreign holdings',
    ],
    summary: 'Personal advisory for individuals with cross-border footprints — promoters with offshore holdings, executives on global compensation, and families managing inter-generational wealth across jurisdictions. Discreet, longitudinal engagements rather than transaction-by-transaction work.',
  },
  {
    slug: 'family-office-support',
    title: 'Family Office Support',
    short: 'Institutional infrastructure for single-family and multi-family office capital.',
    capabilities: [
      'Investment entity structuring and consolidation',
      'Treasury, FX and global allocation reporting',
      'Tax compliance across investment vehicles',
      'Governance, charters and constitutional documents',
      'Succession, trust and estate frameworks',
      'Operating partner due diligence on direct deals',
    ],
    implications: [
      'Cross-jurisdictional reporting on private investments',
      'Substance positioning for offshore vehicles',
      'Governance discipline across generations',
    ],
    summary: 'Family office work treats capital as an institution: governance, investment infrastructure, reporting and tax architecture designed to operate quietly across jurisdictions and generations.',
  },
];

const INDUSTRIES_LIST = [
  {
    slug: 'technology-saas',
    title: 'Technology & SaaS',
    short: 'Subscription, platform and IP-led businesses with cross-border revenue and engineering footprints.',
    contexts: [
      'Inter-company structures across India, US, EU and Singapore',
      'IP ownership and migration positions',
      'Permanent establishment risk on engineering subsidiaries',
      'Equalisation levy, OIDAR and digital tax overlays',
      'Stock-based compensation and global mobility',
    ],
    risks: [
      'Mis-priced engineering services creating residual TP risk',
      'Inadvertent PE through founder presence and contracting',
      'Indirect tax exposure on intermediary mis-classification',
      'Withholding mismatch on cross-border SaaS receipts',
    ],
    summary: 'Software businesses rarely sit cleanly within a single jurisdiction. We advise founders, finance teams and boards on the structures, transfer pricing positions and indirect tax overlays that determine how globally distributed software companies actually pay tax.',
  },
  {
    slug: 'gccs-mnc-subsidiaries',
    title: 'GCCs & MNC Subsidiaries',
    short: 'Indian operations of foreign principals — captives, GCCs and operating subsidiaries.',
    contexts: [
      'Cost-plus, services-PE and attribution analysis',
      'Group reporting alignment to parent GAAP',
      'Secondment, dual employment and economic-employer',
      'India regulatory interface for foreign boards',
      'Statutory audit and group audit coordination',
    ],
    risks: [
      'Margin adequacy under SWD and ITES benchmarks',
      'Attribution to a deemed PE in India',
      'Secondment characterised as fees for technical services',
      'Inadequate inter-company documentation under audit',
    ],
    summary: 'GCC and captive operations sit at the intersection of three jurisdictions — the parent, India and frequently a holding-company location. We advise on the transfer pricing, regulatory and group reporting architecture that lets these operations scale without drift.',
  },
  {
    slug: 'cross-border-businesses',
    title: 'Cross-Border Businesses',
    short: 'Indian-headquartered groups with operations, capital or customers outside India.',
    contexts: [
      'ODI architecture and overseas operating entities',
      'Holding-jurisdiction selection and substance',
      'IP, brand and management-fee flows outbound',
      'Repatriation, FX and treasury policy',
      'BEPS, MLI and Pillar Two alignment',
    ],
    risks: [
      'Round-tripping characterisation on ODI structures',
      'Substance challenges on overseas holdings',
      'Withholding leakage on outbound payments',
      'Treaty access under principal-purpose test',
    ],
    summary: 'For Indian businesses operating across borders, the home-country regulatory regime is often the most consequential variable. We advise on the FEMA, tax and operating-model decisions that shape outbound architecture — and the ones that determine how it ends.',
  },
  {
    slug: 'founders-promoters',
    title: 'Founders & Promoters',
    short: 'Personal positioning for founders, promoters and operating shareholders with concentrated equity.',
    contexts: [
      'Pre-liquidity structuring and residency planning',
      'Trust, family-investment and gifting frameworks',
      'Offshore holding and investment vehicles',
      'ESOP, RSU and secondary participation',
      'Disclosure under Black Money and FA reporting',
    ],
    risks: [
      'Founder PE on cross-border operating entities',
      'Mis-characterised secondary transactions',
      'Inadequate documentation on personal foreign assets',
      'Estate exposure through unstructured holdings',
    ],
    summary: 'Founders and promoters carry firm-level risk in personal capacity. The advisory work is longitudinal: structures put in place before liquidity, reporting positions held across years, and the personal-corporate boundary kept legible to regulators.',
  },
  {
    slug: 'professional-services',
    title: 'Professional Services Firms',
    short: 'Partnerships and operating professionals navigating regulated cross-border practice.',
    contexts: [
      'Partnership architecture and cross-border profit shares',
      'Network firm arrangements and inbound assignments',
      'Personal tax for partners across jurisdictions',
      'Service-PE and economic-employer for inbound consultants',
      'Indirect tax on cross-border professional fees',
    ],
    risks: [
      'Service-PE on inbound consultant engagements',
      'Withholding on cross-border partnership distributions',
      'GST exposure on offshore client billings',
      'Personal residency drift for travelling partners',
    ],
    summary: 'Professional services firms — legal, consulting, technical, design — operate under partnership economics that travel poorly across borders. We advise the firm and its partners as connected matters: structure, profit allocation and personal positions managed coherently.',
  },
];

const INSIGHTS = [
  {
    cat: 'Transfer Pricing', date: '14 Apr 2026', read: '11 min',
    title: 'Operational transfer pricing under Pillar Two: where the year-end true-up no longer holds',
    dek: 'Top-up tax mechanics shift the cost of mis-pricing from the next assessment to the current quarter. The implications for inter-company invoicing rhythm, segmentation and forecast credibility.',
    featured: true,
  },
  {
    cat: 'FEMA', date: '02 Apr 2026', read: '7 min',
    title: 'Overseas Direct Investment: substance, layering and the second-look problem',
    dek: 'A practitioner’s view of where the revised ODI framework will be tested first — and the structures that will struggle to defend themselves.'
  },
  {
    cat: 'International Tax', date: '21 Mar 2026', read: '9 min',
    title: 'Beneficial ownership in 2026: a quieter standard, a sharper instrument',
    dek: 'Recent Indian and international decisions read together suggest that beneficial-ownership tests are converging on a substance-and-conduct standard rather than a documentary one.'
  },
  {
    cat: 'GCC', date: '08 Mar 2026', read: '6 min',
    title: 'Margin adequacy in mature GCCs: the case for segmentation',
    dek: 'As Indian captives move up the value chain, undifferentiated cost-plus benchmarks are increasingly inadequate. Designing segmentation that survives examination.'
  },
  {
    cat: 'Personal', date: '24 Feb 2026', read: '8 min',
    title: 'Returning Indian residents: the first three financial years',
    dek: 'Foreign asset reporting, residency tie-breakers and the structuring decisions that are easier to make before, rather than after, the trigger date.'
  },
  {
    cat: 'GST', date: '11 Feb 2026', read: '5 min',
    title: 'Intermediary services: the long road back from a binary characterisation',
    dek: 'Why the intermediary question continues to absorb disproportionate adjudicatory time, and what export-of-services taxpayers should be doing in the meantime.'
  },
  {
    cat: 'Regulatory', date: '03 Feb 2026', read: '4 min',
    title: 'Disclosure on foreign assets: the practitioner gap closing in 2026',
    dek: 'Information exchange, automatic reporting and a more confident assessment posture are reshaping disclosure conversations with individual clients.'
  },
  {
    cat: 'Transactions', date: '20 Jan 2026', read: '10 min',
    title: 'Locked-box mechanics in cross-border deals: an Indian sell-side view',
    dek: 'Locked-box is increasingly preferred by Indian sellers. The diligence, accounting and SPA architecture that lets it actually close.'
  },
];

Object.assign(window, { EXPERTISE_LIST, INDUSTRIES_LIST, INSIGHTS });
