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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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  • Dan Roman and Aron Joy of KPMG look back on Anson, tracking the background to the case before focusing on the types of structure that could be affected by the decision and how this impact may manifest itself in practice.
  • Rafael Sayagues, Isabel Chiri and Alexandre Barbellion of EY look at the role of Central American countries Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Nicaragua and Panama in the global tax playground and whether a cascading ‘tax bullying’ effect can be seen when global trends are established
  • Roberto Carlos Rivas and Josefina Casals of PwC Chile assess the Chilean Government’s progress in implementing the 2014 tax reform package, reflecting on how certain provisions are impacting foreign investors and looking ahead to see how these measures will sit alongside the implementation of base erosion and profit shifting (BEPS) related measures

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