UK companies investing in India face higher tax rates, significant compliance burdens and restrictions on investment. It is important to identify these in advance so that tax issues do not delay commercial investments. It can be difficult to mitigate taxes on income, but structures can be put in place to mitigate capital gains tax on a future disposal. However, a new Direct Tax Code is being introduced which will affect many existing structures of this type, and greater substance than before will be required in order to take advantage of relief under double tax agreements.