India Clarifies Application of Tax Treaty Principal Purpose Tests

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 …
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