Investors will also need to research possible aspects of owning and managing a tax exemption agreement under the agreement. The direct and indirect transfer of shares in assets held in India is unclear. It will also be interesting to see how the tax authorities investigate the indirect transfer of shares under the India-Mauritius agreement, given that the standard perception under the tax system was that the indirect transfer of shares under the agreement was exempt from capital gains tax and that various court declarations had done the same in different cases. However, AAR held in that judgment that the derogation under the Treaty did not apply to `indirect transfers`. .
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