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

by | 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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