India tax administration issues guidance on application of Principal Purpose Test

24 January 2025|Tax Alerts, National/Federal Taxation, Treaties, Global|India

A new tax Circular provides guidance on how Principal Purpose Test provisions apply in the context of India's tax treaties with other countries.
The Circular is a welcome development as it offers some certainty on tax implications that could affect foreign investors who have invested in India.

Executive summary

On 21 January 2025, India tax administration's Central Board of Direct Taxes (CBDT) issued a Circular¹ providing guidance on application of the Principal Purpose Test (PPT) provisions…

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