CBDT Provides Clarity on Application of PPT in India’s DTAAs, No impact on GAAR, SAAR, or JAAR
CBDT clarifies that the PPT in India’s DTAAs applies only where explicitly provided, without affecting other treaty provisions or domestic anti-abuse rules.
By Kavi Priya - On March 16, 2025 1:52 pm - 2 mins read
The Central Board of Direct Taxes (CBDT) issued a clarification press release regarding Circular No. 01/2025, addressing the application of the Principal Purpose Test (PPT) under India’s Double Taxation Avoidance Agreements (DTAAs). The CBDT stated that the PPT provision applies only to DTAAs that explicitly contain a PPT clause. This means the Circular does not…
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