The Resource Tiger Global International II Holdings, Mauritius v Commissioner of Income Tax (International Tax) : AAR/04/2019 / AAR/05/2019 / AAR/07/2019

Tiger Global International II Holdings, Mauritius v Commissioner of Income Tax (International Tax) : AAR/04/2019 / AAR/05/2019 / AAR/07/2019

Label
Tiger Global International II Holdings, Mauritius v Commissioner of Income Tax (International Tax) : AAR/04/2019 / AAR/05/2019 / AAR/07/2019
Title
Tiger Global International II Holdings, Mauritius v Commissioner of Income Tax (International Tax) : AAR/04/2019 / AAR/05/2019 / AAR/07/2019
Creator
Contributor
Subject
Language
eng
Summary
Judgment by the Authority for Advance Rulings (Income Tax) New Delhi, decision date 26 March 2020. The applicants in these cases were three investment companies incorporated in Mauritius and holding Category 1 Global Business Licences as well as being resident in Mauritius for purposes of Mauritius taxation. The companies held shares in a Singapore company, Flipkart Private Ltd, which in turn held interests in companies having a business activity in India. In August 2018 the three Mauritius companies transferred certain of their shares in the Singapore company to a Luxembourg purchaser. They contended that the gain on the disposal of the shares in the Singapore company was taxable only in Mauritius by virtue of the Mauritius-India double taxation convention. The Indian Revenue ruled that the applicants would be liable for tax on the capital gains and the applicants applied to the Authority for Advance Rulings. The Authority for Advance Rulings refused to issue a ruling on the ground that the ruling was in respect of a transaction which was designed prima facie for the avoidance of income tax
Citation source
In: International tax law reports. - London. - Vol. 23 (2020), part 1 ; p. 28-59
http://bibfra.me/vocab/relation/comm
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http://library.link/vocab/creatorName
Goradia, S
Geographic coverage
  • Asia
  • Africa
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • advance ruling
  • tax treaty
  • capital gains tax
  • tax avoidance
  • central management and control
  • beneficial ownership
Label
Tiger Global International II Holdings, Mauritius v Commissioner of Income Tax (International Tax) : AAR/04/2019 / AAR/05/2019 / AAR/07/2019
Instantiates
Publication
Label
Tiger Global International II Holdings, Mauritius v Commissioner of Income Tax (International Tax) : AAR/04/2019 / AAR/05/2019 / AAR/07/2019
Publication

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