Tax Residency Certificate (TRC)

On 15th January 2026, in a ruling, the Supreme Court (SC) set aside a Delhi High Court order that was in favour of Mauritius-based Tiger Global International (TGI), and ruled that the capital gains arising out of its $1.6 billion-worth of stake sale in Flipkart, in 2018, is taxable by Indian authorities.

  • The ruling by the SC signals the end of mechanical treaty benefit claims based solely on tax residency certificates (TRCs).

What is Tax Residency Certificate (TRC)?

  • Also called a certificate of residence for tax purposes or certificate of tax domicile, it is a legal document released by the tax ....
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