India-Cyprus tax treaty to be amended in order to tax capital gains and incorporate limitation of benefits clause

It has been reported that India and Cyprus have reached a consensus to amend the India-Cyprus tax treaty in order to tax capital gains earned by a resident of Cyprus from disposal of shares of Indian companies, in India.

Under Art. 14 of the current treaty, capital gains on sale of shares of Indian companies are exempt from tax in India. Cyprus does not impose capital gains tax on its residents, and with India exempting the capital gains under the treaty, inve…