The Delhi High Court (HC) has recently issued a judgement overturning a ruling issued by the Authority for Advance Ruling (AAR) in 2020. The transaction under consideration related to the availability of treaty benefits on the transfer of shares of Flipkart Singapore by Tiger Global entities.
The HC decision deals with certain important issues relevant for foreign investors namely, sanctity of Tax Residency Certificate, concept of beneficial ownership, interplay of tax treaty provisions vis-à-vis domestic anti-abuse provisions and applicability of tax treaty provisions on indirect transfers.
Grant Thornton Bharat invites you to a webinar to decode this decision with subject matter tax experts and distinguished legal professionals.
Key discussion points
- Observations and conclusions by the HC
- Takeaways from the HC judgement
- Way forward for taxpayers
Speakers
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Grant Thornton BharatRajeshree Sabnavis (Moderator) -
IndiaAjay Vohra -
GurugramRicha Sawhney -
Grant Thornton BharatPramod Kumar
