Tiger Global Verdict: India's Tax Net Widens for Foreign Investors

• The Supreme Court's Tiger Global verdict strengthens India's indirect transfer tax provisions, potentially expanding the tax net for foreign investors.
• This ruling could lead to billions of dollars in new tax demands for foreign portfolio funds, buyout firms, and overseas investors in Indian companies.
• The verdict particularly impacts funds using multi-layered investment structures to avoid indirect transfer provisions.
• The Supreme Court emphasized 'substance over form,' allowing the tax department to deny treaty benefits if an offshore entity lacks commercial substance.
• Experts believe this judgment will refocus attention on tax treaty cases concerning capital gains income, especially for indirect transfers.

Why It Matters: The Tiger Global verdict significantly strengthens India's indirect transfer tax laws, impacting foreign investment structures.