Treaty Shopping: Abuse of Double Taxation Avoidance Agreement (DTAA): Special Focus on the Case Study of India’s DTAA With Mauritius and the MLI Framework

By Mohak Thukral
The essay is an attempt to explain the concept of ‘Treaty Shopping’ and traces the response of the Indian Government in tackling this form of Treaty Abuse. The paper will analyse India’s DTTA obligation with Mauritius, trace the trajectory of steps taken by the government including passing of GAAR rules and the judicial decisions starting from the Azadi Bachao Andolan Case to the recent Vodaphone Case while dealing with Treaty Shopping. The essay also briefly explains the recent developments in the international tax regime, including the ratification of the Indian Government of ratifying the Multilateral Convention (MLI), and its potential impact on the Indo-Mauritius Tax Treaty.