Pinky Mehta, CFO of Aditya Birla Nuvo Limited and Rajeshree Sabnavis, partner at BMR & Associates, analyse recent developments around the constitution of a place of effective management (PoEM) in India, looking at how these developments tie in with global discussions on the theme of substance-over-form.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
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