India: Rights entitlements not company shares for purposes of Ireland treaty (Tribunal decision)

Gains from transfer of rights entitlements thus not taxable in India under treaty

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March 20, 2025

The Mumbai Bench of the Tribunal held that rights entitlements were distinguishable from shares in a company and thus gains from the transfer of the rights entitlements were not taxable in India under the India-Ireland income tax treaty.

The case is: Vanguard Emerging Markets Stock Index Fund A Series of VISPLC v. ACIT

Read a March 2025 report prepared by the KPMG member firm in India 

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