The Indian tax authorities recently held in Ardex that taking advantage of a tax treaty by itself is not objectionable treaty shopping. Not every transaction that seeks to benefit from a treaty is equivalent to tax evasion. Ravishankar Raghavan of Majmudar & Co discusses the ruling and provides a few steps to demonstrate substance in intermediary locations including Mauritius.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
Rolling out the global minimum tax has increased complexity, according to Baker McKenzie; in other news, Donald Trump has announced a 25% tariff on countries doing business with Iran