India's Central Board of Direct Taxes has issued Circular No. 01/2025, which clarifies the application of the principal purpose test (PPT) provisions in India's tax treaties. This includes bilaterally agreed PPT provisions, as well as the PPT provision implemented via the BEPS MLI. One of the key points of the Circular is that PPT provisions only apply prospectively. Where PPT provisions have been incorporated through bilateral processes (such as in the tax treaties with Chile, Iran, Hong Kong, China, etc.), the PPT provisions apply from the date of entry into force of the treaty or the amending protocol incorporating the...