The European Court of Justice’s (ECJ) second judgment in the Franked Investment Income Group Litigation (FII GLO) clarifies when EU taxpayers can rely on free movement of capital for outward investments into non-EU jurisdictions. It also highlights the need for an answer regarding inward investment from non-EU taxpayers.
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Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
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