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Analysis: India-Hong Kong tax treaty is filled with anti-avoidance features

Updated : April 23, 2019 12:30 PM IST

The India-Hong Kong treaty was subsequently ratified by the two countries in November 2018 and has become applicable in India from April 1, 2019
Being a treaty of a more recent vintage, it is brimming with a number of anti-avoidance features including a domestic law override for anti-avoidance, a Principal Purpose Test and a rule targeting dual residency
With an accent on tax information exchange, the Hong Kong treaty incorporates a powerful all-encompassing information exchange clause that covers all taxes (including wealth tax, excise and customs duty, GST and sales and VAT)
Analysis: India-Hong Kong tax treaty is filled with anti-avoidance features
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