Anandu Unnikrishnan

Email : anandu.unnikrishnan@resolutpartners.com

Phone : +91 80958 10931

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Overview

Anandu advises and represents clients on international tax issues and tax structuring across both contentious and non-contentious mandates. He has acted for several PE/VC funds and multi-national corporations on their Indian inbound and outbound investments and is regularly instructed to lead complex tax proceedings at all appellate levels across several sectors, including IT & ITeS, financial services, industrials, and infrastructure.

He has advised the Government of India on taxation of financial markets transactions in the lead up to its annual budget announcements. He has also previously advised the Institute of Chartered Accountants of India and the Government Law College, Bombay in setting up their post-graduate diploma programmes in international tax and securities taxation respectively.

Representative Matters

  • Advised one of the world’s largest investment banks on the Indian and international anti-avoidance implications (including under BEPS-MLI) of restructuring its global equities derivatives business following Brexit.
  • Advised Avenue Capital on the tax issues involved in its acquisition of a controlling stake in one of India’s largest asset reconstruction companies and advised on pass-through taxation of income from securitized loan assets.
  • Acted for one of India’s largest general insurance companies in underwriting the very first buy-side M&A tax insurance underwritten by an Indian public-sector insurer.
  • Represented Tiger Global before the Authority for Advance Rulings and the Delhi High Court on applicability of indirect transfer tax in relation to its USD 2.8 billion exit from Flipkart.
  • Successfully represented Mapletree Investments before the Income-tax Appellate Tribunal in one of first Indian tax disputes on beneficial ownership of income from a hybrid instrument.
  • Successfully represented Aberdeen Standard before the Bombay High Court in an INR 252 million tax dispute relating to carry forward of losses following an offshore restructuring.
  • Advised the Government of India (Department of Economic Affairs) on taxation of financial markets transactions (taxation of dividend, buybacks, and Cat-III AIFs), which directly resulted in the abolition of dividend distribution tax vide Finance Act, 2020.

Education

B.A., LL.B. (Hons.), National Law School of India University

Publications

  • ‘Tax residency in the time of COVID’, LiveLaw Publication, 2021
  • Monthly tax updates to the India Business Law Journal, 2018 –2019
  • ‘Virtual Permanent Establishments: Indian Law and Practice’, Intertax, Vol. 46, Issue 6/7, Kluwer Law International, 2018
  • ‘Indian tax tribunal adopts expansive view of PE in MasterCard ruling’, MNE Tax, 2018
  • ‘India developing “significant economic presence” test to increase taxation of multinational firms’, MNE Tax, 2018

Research

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Private Credit: Interest on NCDs recharacterized as dividends 
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Denial of tax treaty benefits: Blueprinting defence strategies for PE funds - A tax litigation perspective
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Top 5 Tax Considerations When Structuring Debt Investments in India
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