Officials can deny benefits if tax relief found sole motive

India has implemented a Principal Purpose Test in the India-Mauritius Double Taxation Avoidance Agreement. This test allows tax authorities to deny benefits when tax relief is a principal purpose. The amendment, effective from August 2026, impacts various foreign investors using Mauritius for investments. The change affects significant cumulative foreign direct investment inflows into India from Mauritius. Experts believe this will alter how investment structures are evaluated under the treaty.