evidence: On May 10, 2016, India and Mauritius signed a protocol amending the India-Mauritius double income tax treaty that would, among other things, permit India to tax a Mauritian resident on capital gains arising from the sale of shares of Indian companies acquired on or after April 1, 2017. Although equity investments made prior to April 1, 2017 will not be subject to the protocol, the protocol will have a profound impact on foreign investors’ use of Mauritian entities to structure inbound equity investment into India. Foreign equity investors will likely turn away from Mauritius and toward jurisdictions that have more favorable tax treaties with India such as the Netherlands, Cyprus (although it is currently blacklisted in India) and UAE. Although Singapore historically has been among the more favored countries for inbound India investment, the protocol will also apply to Singapore investors because the India-Singapore double income tax treaty links its capital gains tax regime to the capital gains tax regime in the India-Mauritius double income tax treaty.