Under GAAR, foreign investors have to prove they are not operating from a jurisdiction just to take advantage of the tax treaty. To determine if an entity has a ‘material substance’ in that jurisdiction, tax authorities see if an entity has an office with sufficient staff and conducts operations from there.
P-Notes -- offshore derivative instruments issued by brokers to foreign investors not registered in the country -- are now being dealt via France, the article quoted a lawyer as saying.
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