India: Commissioner of Wealth Tax, Rajkot v Estate of Late HMM Vikramsinhji of Gondal

The Supreme Court of India (SC) in a recent ruling [Commissioner of Wealth Tax, Rajkot v. Estate of Late HMM Vikramsinhji of Gondal (Civil Appeal No. 2312 of 2007)] has held that the Indian resident beneficiaries of an offshore discretionary trust shall not be subject to tax on the trust’s income until the trustees or ‘discretion exercisers’ exercise the discretion and make a distribution of income to the beneficiaries.