How India’s Tiger Global Ruling Collapses Treaty Residence Into an Anti-Abuse Inquiry
India’s Supreme Court in the Tiger Global ruling applied GAAR to question the very existence of treaty residence, overturning the long‑standing separation between residence determination and anti‑abuse review. The case involved a U.S. private‑equity fund using Mauritian holding companies to acquire Flipkart, which the tax authority challenged under the India‑Mauritius DTAA. The Court held that a valid Tax Residency Certificate alone cannot shield a taxpayer from an anti‑abuse inquiry, effectively allowing GAAR to invalidate treaty benefits. This decision reshapes how multinational investors assess treaty protections in India.
Privacy and Tax Information Powers
The European Court of Human Rights ruled that Italy’s tax authority’s broad power to obtain banking data without adequate safeguards breaches Article 8 of the European Convention on Human Rights. The Court held that the statutory discretion is unfettered and that...
The Contents of Highlights & Insights on European Taxation, Issue 4, 2026
The EU Court of Justice ruled on 12 March 2026 that Spain’s Article 96 exclusions on client entertainment and recreational expenses fall within the stand‑still clause of Article 176 of the VAT Directive. The judgment confirms a functional interpretation of the clause, allowing later‑acceding...
Taxation as a Driver of Energy Transition: How China Rewrote Its Vulnerability to Oil Shocks
China’s resilience to recent oil‑supply shocks stems largely from its environmental taxation regime rather than pure geopolitics. The 2018 Environmental Protection Tax (EPT) internalized pollution costs, making coal and heavy industry more expensive and accelerating renewable‑energy investment. Empirical evidence shows...
The Alchemy of Agreements: Examining India’s FTA’s in an Evolving Global Order
India has accelerated its free‑trade agreement agenda, signing deals with the UK, EU, UAE, Australia, New Zealand and others between 2024 and 2026. Merchandise exports have risen to $451 billion, up from $314 billion a decade earlier, while GDP is projected to grow...
The Contents of Highlights & Insights on European Taxation, Issue 3, 2026
The European Commission has drafted a Regulation to create EU Inc., a unified limited‑liability company form usable in every Member State. The proposal targets legal fragmentation, offering fully digital, EU‑wide formation, filing and cross‑border operations, including a 48‑hour fast‑track registration...
Global Value Chains and the Separate-Entity Principle: Rethinking Intra-Group Relationships in Corporate Law and International Tax Law
Global value chains now account for nearly 70% of world trade, linking design, production, branding, and sales across multiple jurisdictions. This economic integration challenges the traditional separate‑entity principle that underpins corporate and international tax law, which treat each group company...