Case Law Details
Re. Tiger Global International II Holdings, Mauritius & Ors (Authority for Advance Rulings New Delhi)
Facts:
♠ Tiger Global International (II, III, IV) were the applicants, the Mauritius based companies which holds several shares in the Flipkart Private Limited, the Singapore based Company, the company which derive its substantial value from the assets located in the India.
♠ The Mauritius based companies had made investments in the Flipkart (Singapore) in various tranches during the period from Oct-2011 to Apr-2015, therefore, these companies were eligible to get benefit of grandfathering clause as per amended DTAA between India & Mauritius.
♠ On 18.08.2018 all the three applicants transferred certain shares of Singapore Co. to Fit Holdings S.A.R.L. (Buyer), a company incorporated under the laws of Luxembourg. These transfers were undertaken as part of a broader transaction involving the majority acquisition of Singapore Co. by Walmart Inc., a company incorporated in the United States of America, from several shareholders, including the applicants.
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