Indian Tax Tribunal rules on re-domiciliation and its impact on treaty entitlement
Executive summary
The Mumbai Tax Tribunal has ruled in favor of non-Indian taxpayers that the re-domiciliation of a taxpayer does not affect treaty entitlement. The re-domiciled taxpayer was held to be entitled to the tax treaty benefits between India and the country of re-domiciliation.1 The Tribunal noted that re-domiciliation of the company by itself cannot lead to denial of treaty entitlem…
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