Embed Size (px)
Citation preview
Mirror, mirror on the wall, please show the purpose to all
28 April 2015
Rishi Joshi, associate member of the Institute of Chartered Accountants of India, analyses recentcontroversy and litigation on the issue of indirect share transfers.
An indirect transfer occurs when an investing foreign company (IFC) invests in a target company(TC) indirectly through an interposing offshore company or companies (IC) solely incorporated forchanneling the investments in the TC. The subsequent stake sale in the TC achieved through thedisposal of the shares of the IC and realisation of the gains arising from the disposal of the shares ofthe IC goes untaxed in the source state where the TC is located.
In the wake of various indirect asset transfers effected in transactions around the world with hugetax implications, quite a few of the non-OECD countries have brought legislative changes to dealwith the situation, which may be seen as an acknowledgement that source countries are beingfleeced of revenue due to them.
In one of the recent cases in 2012, the Mozambican government approved completely...
This article is locked content, available to current subscribers or trialists.
Current subscribers or trialists - Please log in to view this article in full.
New users - Please take a free 7 day trial.
Expired subscribers or trialists - Please subscribe to gain immediate full access.
If you think you've received this message in error, please contact your account manager, NickBurroughs:
Email: [email protected], Tel: +44 (0)207 779 8379
Subscribe now
Subscribe today to gain full access to International Tax Review.
Subscribe
Free trial
Take a free trial now and gain 7 days of full access to International Tax Review.
Free trial
http://feedproxy.google.com/~r/internationaltaxreview/fLlp/~3/jvhUycOVqGc/Mirror-mirror-on-the-wall-please-show-the-purpose-to-all.html
