International Tax Update: Landmark Ruling on SC Lowy: Principal Purpose Test under the India-Luxembourg Tax Treaty

International Tax Update: Landmark Ruling on SC Lowy: Principal Purpose Test under the India-Luxembourg Tax Treaty

In a precedent-setting decision, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) ruled in favor of SC Lowy P.I. (Lux) S.A.R.L., addressing the applicability of the Principal Purpose Test (PPT) under the India-Luxembourg Double Taxation Avoidance Agreement (DTAA), as modified by the Multilateral Instrument (MLI). This judgment is significant as it marks the first application of the PPT by an Indian tribunal in the context of cross-bor…