The Supreme Court has ruled that a Tax Residency Certificate (TRC) is not conclusive proof of eligibility for Double Taxation Avoidance Agreement (DTAA) benefits, reversing a High Court decision. This judgment unsettles long-standing investment structures and introduces uncertainty for foreign investors, despite grandfathering provisions for pre-2017 investments.
Does 'Tiger Global' leave investors confused, or finally put economic substance over legal form?
