The India Authority for Advance Rulings (AAR) recently issued a ruling that clarifies the taxation of the indirect transfer of Indian property with regard to the provisions of the Income Tax Act (ITA) and the 1995 Germany-India tax treaty. The ruling concerns the German company GEA Refrigeration Technologies GmbH (GEA). In 2010, GEA entered into a share purchase agreement for approximately EUR 40.5 million to acquire an unrelated Germany company, Bock Kaltemaschinen GmbH (Bock Germany), which held various subsidiaries including 100% of an India subsidiary, Bock India Private Limited (Bock India). GEA applied to the AAR for a ruling to...