Foreign portfolio investors (FPIs) are jittery as recently revised India-Singapore tax treaty has created confusion over general anti-avoidance rule (GAAR) overriding bilateral tax treaties. This is despite the fact that a high-level panel, led by tax expert Parthasarathi Shome, had recommended that GAAR should not override bilateral tax treaties. A clause in the revised double taxation avoidance agreement (DTAA) with Singapore says domestic laws such as GAAR will override the treaty, even as the pact has a limitation-ofbenefits clause. The industry is now looking for a clarification on this aspect. One of the key concerns of foreign investors is how GAAR would apply in case an investor is availing benefits under DTAA. “It should be clarified that provisions of GAAR would not be invoked if the tax treaty itself contains antiavoidance and anti-abuse provisions like limitation-of-benefits clause. Also, with so much global thrust on base erosion and profit shifting (BEPS), it sh