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Direct Tax
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
February 11, 2026
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  • The Year of the Sheep, now drawing to a close, has been a signature year both economically and fiscally for China. China had surpassed the US as the world's largest economy, in purchasing power parity terms, in 2014. It had similarly become the world's largest recipient of foreign direct investment (FDI), also overtaking the US, in that year. Remarkably, while China takes the top position as a recipient of FDI, Chinese outbound direct investment (ODI) is projected to overtake FDI for 2015 as a whole, making China a net exporter of capital. Projections further show China overtaking the US in ODI terms to become the world's premier source of ODI within a short few years. There is no doubt that China is becoming ever more central to the global economic order. Nevertheless, as the Chinese government seeks to shift her economy from reliance on investments, exports and heavy industries to a more consumption and service sector-driven model, the pace of economic expansion in China will ease off before picking up again. In the meantime, the government will go to every length to safeguard her tax revenues.
  • The roll out of enhanced tax exemptions for offshore private equity funds, the improvement of intellectual property and treasury centre incentives, the expansion of Hong Kong’s tax treaty network and the putting in place of arrangements for automatic exchanges of information are the focus areas of this article by Ayesha Macpherson Lau, Darren Bowdern, Michael Olesnicky, and Curtis Ng
  • The progress with, and challenges of, rolling out the FATCA and CRS technology and platforms in Hong Kong and Chinese financial institutions is the focus of this chapter by Charles Kinsley, Khoonming Ho and Lewis Lu

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