Advance ruling allows partnership as a tax planning tool
April 29, 2009
In India, the advance ruling in the case of Canoro Resources addresses the applicability of domestic anti-avoidance provisions to transfers between partners and foreign partnerships.
The petitioner, a Canada-based exploration and production of petroleum and natural gas company, held participating interests in certain oil blocks in India. As part of a business restructuring project, the petitioner proposed to transfer its participating interest in one of the blocks as capital contribution to a partnership to be formed in Canada between it and its wholly owned Canadian subsidiary. The restructuring was undertaken with a view to attracting other potential investors.
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