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CBDT issues guidance on application of Principal Purpose Test
This Tax Alert summarizes a recent Circular No. 01/2025 dated 21 January 2025 (Circular) issued by the Central Board of Direct Taxes (CBDT) providing guidance on application of the Principal Purpose Test (PPT) provisions in the context of Indian tax treaties.
Broadly, the Circular clarifies that PPT provisions are to be applied prospectively from (i) the date of entry into force of the treaty/amending protocol whereby PPT was introduced pursuant to bilateral negotiations; or (ii) the effective date of provisions introducing PPT into the treaty through Multilateral Instrument (MLI).
Further, it also clarifies that grandfathering benefit with reference to capital gains arising from transfer of shares of an Indian company by treaty residents of Mauritius, Singapore and Cyprus in respect of shares acquired prior to 1 April 2017 will be outside the purview of PPT and instead be governed by specific provisions of the respective tax treaty.