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Re-domiciliation is a reality, but it may invoke inquiries to test the substance in a new jurisdiction to avail a tax treaty benefit

September 17, 2021[2021] 130 taxmann.com 272 (Article)
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In this case, the taxpayer was initially registered in the British Virgin Islands (BVI) and thereafter re-domiciled in Mauritius, upon the Registrar of Companies issuing a ‘Certificate of Incorporation’.
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