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.
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Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard