Legal analysis and practical guidance on cross-border business, disputes, corporate, employment and IP matters across India and the UAE — including the Legal Help Desk, our Q&A column on the problems clients actually meet.
Two benches of the Income Tax Appellate Tribunal have held that India cannot use the principal purpose test (PPT) in the Multilateral Instrument (MLI) to deny relief under a tax treaty until the Government notifies the MLI’s changes to that particular treaty. As of 29 October 2026 we found no such notification and no reported […]
The Protocol amending the India–Mauritius DTAA entered into force on 10 August 2026. It adds a principal purpose test (new Article 27B): a Mauritius fund holding Indian investments can now be denied treaty benefits on an item of income if obtaining the benefit was one of the principal purposes of an arrangement. The Protocol contains […]
On 22 October 2026 the Court of Appeal in London dismissed India’s appeal in RAKIA v India, so a claim based on a 12% stake in an Indian project company goes to arbitration on the merits under the 2013 India–UAE bilateral investment treaty (BIT). Which treaty applies to a dispute depends on when the events […]
The India–Mauritius BIT was terminated with effect from 22 March 2017, and its sunset clause protects investments approved or made before that date until about 22 March 2027, unless a contract or approval granted to the investor provides a longer period. A group that holds Indian assets through Mauritius and has a dispute over a […]
No international worker PF judgment yet binds the whole country. The Karnataka High Court struck down paragraph 83 of the EPF Scheme 1952 on 25 April 2024; the Delhi High Court upheld it on 4 November 2025, and the Supreme Court reportedly issued notice in a further challenge in March 2026. Counsel handling past demands […]
The sovereign wealth fund exemption in India keeps dividend, interest and long-term capital gains out of total income where a notified sovereign wealth fund, a notified pension fund, a UAE-resident wholly owned subsidiary of the Abu Dhabi Investment Authority (ADIA) or Saudi Arabia’s Public Investment Fund (PIF) invests in Indian infrastructure on or before 31 […]
In Hyatt International Southwest Asia Ltd v ADIT, the Supreme Court held that a Dubai company had a fixed-place permanent establishment (PE) in India under Article 5(1) of the India–UAE tax treaty, although it had no exclusive or designated space in the Indian hotels it oversaw. The Court rested the finding on “pervasive and enforceable […]