India Circular on Relief from Indirect Transfer Provisions for Multi-Tier Investment Structures

India's Central Board of Direct Taxes has issued Circular No. 28/2017, which addresses the taxation of indirect transfers involving an investment fund or a venture capital company or a venture capital fund (specified funds) that are set up as multi-tier investment structures. Section 9(1)(i) of the Income-tax Act, 1961, sets out the provisions for income deemed to accrue or arise in India, including income from the transfer of foreign shares or interests that directly or indirectly derive th…