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India Clarifies Recent Guidance on Application of Tax Treaty Principal Purpose Tests

20 March 2025

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Approved Changes

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India

India's Central Board of Direct Taxes issued a press release on 15 March 2025 to clarify Circular No. 01/2025. As previously reported, Circular No. 01/2025 was issued on 21 January 2025 to provide guidance on the application of the principal purpose test (PPT) provisions in India's tax treaties, including bilaterally agreed PPT provisions, as well as the PPT provision implemented via the BEPS MLI. The release clarifies that the Circular only applies in relation to PPT provisions in tax treaties that contain such provisions and is not intended to interfere or interact with any other provisions of a treaty, including...