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Direct Tax
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, and rejects protection for indirect transfers and tightening conditions for Mauritius‑based investors claiming DTAA relief
February 11, 2026
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  • The 2015 enhancements to China’s restructuring tax relief rules, the challenging new indirect offshore disposal rules in SAT Announcement 7, developments in financial instrument tax classification and the revamped tax treaty relief procedures are the focus of this article by KPMG’s John Gu, State Shi, Josephine Jiang, Chris Mak and Yvette Chan.
  • François Auger and Julia Wang of Blake, Cassels & Graydon explore recent M&A-related developments in Canadian tax law aimed at clarifying and expanding the use of the corporate tax ‘bump’ tool.
  • Rolf Wüthrich and Noëmi Kunz-Schenk of burckhardt provide an update on the new Swiss approach to net wealth taxation of shares in start-ups.

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