India’s AAR has rejected the NIL withholding tax applications made by three Mauritius based companies

Jun 7, 2020

India’s Authority for Advance Rulings has, recently, rejected the nil withholding tax applications made by US-based hedge fund, Tiger Global Management’s three Mauritius-based companies, in respect of capital gains arising out of the $16-billion Walmart-Flipkart deal in May 2018. Tiger Global was one of the prominent shareholders in India’s homegrown e-commerce major, Flipkart.

The issue once again seems to be a lack of commercial substance at the Mauritius level.

We are waiting for a copy of the AAR order, and quite clearly, the last word on the subject has not been spoken.

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