In the latest episode of the ELP Podcast Series: India-Mauritius Tax Treaty: Unpacking the Impact of the 2025 circular on grandfathered investments and PPT scrutiny, Sanskriti Tiwari, Assistant Manager Corporate Communications, speaks to our Partner Rahul Charkha, and Feroz Hematally, Regional Tax Head at IQEQ Mauritius, for a deep dive into the evolving landscape of the India-Mauritius Tax Treaty. The discussion unpacks how Mauritius became a favored investment route into India, offering tax-free exits on investments made before 2017, and how the 2017 protocol shifted taxing rights to India for subsequent investments. Fast forward to 2024, uncertainty loomed over whether the Principal Purpose Test (PPT) could override these grandfathered benefits.

A game-changing January 2025 circular finally put concerns to rest, confirming that pre-2017 investments remain protected. The conversation also highlights why investors must maintain economic substance to avoid scrutiny, as tax authorities continue to assess the legitimacy of transactions. With unresolved questions around Tax Residency Certificates (TRCs), the episode offers key insights into navigating compliance challenges in an ever-evolving tax landscape. The episode concludes with key recommendations for clients from both India and Mauritius perspective, including proactive structure reviews, case-by-case evaluations and continued vigilance regarding evolving tax regulations

The Union Budget, 2024 proposes much needed amendments addressing significant issues for the Insurance Sector, in line with the recommendations made in the 53rd meeting of the GST Council. The proposals come in the background of high-stakes litigation faced by the insurance sector, cumulating to tax demand of several thousand crores. These proposals along with recent Circulars for the Insurance sector are expected to address these litigious issues. However, a finer reading of the proposed amendments and clarifications would suggest that certain aspects would require deeper deliberation to assess actual impact on existing litigation.

In this context, please tune into our podcast wherein our Partner Stella Joseph and Principal Associate Rushil Shah, discuss the implications of these GST proposals for the insurance sector.

Pursuant to recommendations of the 53rd meeting of the GST Council, the Central Board of Indirect Taxes and Customs (CBIC) has issued various Circulars clarifying positions as regards GST treatment of certain transactions. These include three Circulars issued for clarifications on GST treatment of Employee stock ownership plan (ESOP) transactions, valuation of cross border related party transactions and issuance of loans / borrowings to related parties.

In this episode of ELP Podcast Series, "Positive GST Circulars for related party transactions", Harsh Shah (Partner) and Ruchita Shah (Associate Partner) discuss these positive clarifications issued with respect to GST treatment of related party transactions which, they believe, would reduce litigation and promote ease of doing business in India.