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23 August 2026

Foreign investment in India

The topic concerns the India-Mauritius DTAA and the Principal Purpose Test, which are specific, examinable instruments of international taxation and investment policy directly impacting India's capital inflows.

1 min read Day 11 of 15 2 questions 1 prelims

Notes

  • Mauritius remains a significant source of Foreign Direct Investment (FDI) for India, contributing $6.6 billion (11.2% of total FDI) in 2025-26.
  • Cumulative FDI from Mauritius between April 2000 and March 2026 reached $186 billion, representing nearly 25% of total inward FDI.
  • The India-Mauritius Double Taxation Avoidance Agreement (DTAA), signed in 1982, has been the primary framework for bilateral investment flows.
  • The 2016 Protocol introduced source-based taxation of capital gains on shares, shifting Mauritius from the top source of FDI to the second or third largest.
  • The 2024 amendment introduced the Principal Purpose Test (PPT), allowing India to deny tax benefits if the primary objective of an investment structure is tax avoidance.
  • The PPT amendment aims to prevent the use of shell companies for treaty shopping while ensuring genuine investment flows.
  • India's economic fundamentals, including market size, ongoing reforms, and digital transformation, are cited as key drivers for sustained investor confidence.
  • India aims to achieve a $5 trillion economy by the 2028-2029 fiscal year, necessitating significant capital inflows.

Part of a longer story

This is day 11 of 15 in U.S. policy on imports linked to forced labour, which has been running since 15 July 2026. Reading it whole is usually worth more than reading today alone — the exam asks how something developed.

Questions

  1. Discuss the evolution of the India-Mauritius Double Taxation Avoidance Agreement (DTAA) and its impact on regulating foreign investment flows into India. 150 words
    Attempt this — 150 words in 8 min
    0 / 150 words 8:00
  2. How do international tax treaties and anti-avoidance measures like the Principal Purpose Test (PPT) balance the need for attracting Foreign Direct Investment with the requirement to prevent base erosion and profit shifting? 250 words
    Attempt this — 250 words in 11 min
    0 / 250 words 11:00

Prelims

  1. What is the primary objective of the 'Principal Purpose Test' (PPT) introduced in the amended India-Mauritius Double Taxation Avoidance Agreement?