The new Mauritius: Gift City has emerged as a rival—at least for FPIs trading futures and options
Since such a fund takes no recourse to any treaty, an entire layer of controversy disappears—no treaty shopping, no principal purpose test, no limitation of benefits clause and no debate over treaty substance. India’s General Anti-Avoidance Rule (GAAR) framework goes further by specifically carving out FPIs that do not resort to any treaty benefit, placing them beyond the reach of GAAR itself. The structure rests entirely on Indian law, instead of a bargain struck with another country.
