NishithDesai：2025年印度对离岸直接转移征税报告（英文版）

The transfer is only of the share or interest of the entity that holds the asset (directly or indirectly), but that occurs in another jurisdiction, either in the jurisdiction of the residence of the seller or in a third jurisdiction. Hence, when the interest in the asset gets transferred, albeit indirectly, the Source Jurisdiction is deprived of the tax revenue arising out of such transfer. The tax treatment of such Indirect Transfers has emerged as a contentious issue, particularly in develo