PwC India announced that the Indian Finance Ministry’s amendment, approved by both India and Mauritius, has taken effect on Aug 10 2026, leaving pre‑2017 investments untouched.
Under the PPT, new treaty claims must be evaluated, but the grandfathering clause protects existing investments, as clarified in the 2025 Central Board of Direct Taxes circular.
While Mauritius, Singapore and Cyprus treaties shield older stakes, other agreements might invoke both GAAR and PPT for future benefits, according to Kunal Shah.
Investors should watch for upcoming treaty claims and ensure compliance, as authorities can still scrutinize benefits on a case‑by‑case basis.