Taxability of capital gains on transfer of shares of a wholly owned Indian subsidiary by a non resident parent company to a non resident

AAR Ruling: Capital gains arising upon the transfer of shares of a wholly owned Indian subsidiary by a non resident parent company to a non resident would not be liable to tax as per the India-Netherlands DTAA [KSPG Netherlands Holding B.V.– AAR No. 818 of 2009].

Facts:

KSPG Netherlands Holding B.V. (applicant), is a company incorporated in Netherlands on November 6, 2008 with its registered office in Amsterdam. PG India is the private limited company incorporated under th

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