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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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  • Joost Vreeswijk and Ai-Leen Tan examine the impact that BEPS Action 7 will have on centralised operating models, and look at changes which multinationals should be considering to guard against exposure to the new rules.
  • Channing Flynn and Stephen Bates discuss the specific issues related to profit shifting in the fast-changing digital economy.
  • Sarah Churton, Ellis Lambert and Ian Dennis explain how the BEPS Action Plan is changing the tax landscape for intangible assets, and what this means for taxpayers.

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