Background and Facts in brief
Delhi High Court recently overturned an order of Authority of Advance Rulings (‘AAR’)1 which denied private equity firm Tiger Global tax exemption under the India-Mauritius Double Tax Avoidance Agreement (‘DTAA’).
The Petitioner (‘TGI entities’), incorporated and resident under the laws of Mauritius, acquired shares in Flipkart, a Singapore-based company. Flipkart holds shares in several Indian companies operating the e-commerce platform Flipkart.com in India, implying that the value of Flipkart’s shares is significantly derived from Indian assets.
For further information, please contact:
Shivi Rastogi, Partner, Amicus
shivi@amicusservices.in