Switzerland suspends most favoured nation status to India
New Delhi, Dec 13: The Swiss government has suspended the most favoured nation status (MFN) clause in the Double Taxation Avoidance Agreement (DTAA) between India and Switzerland, potentially impacting Swiss investments in India and leading to higher taxes on Indian companies operating in the European nation.
According to a December 11 statement by the Swiss finance department, the move follows the Supreme Court of India last year ruling that the MFN clause doesn't automatically trigger when a country joins the OECD if the Indian government signed a tax treaty with that country before it joined the organization.
India signed tax treaties with Colombia and Lithuania that provided tax rates on certain types of income that were lower than the rates it provided to OECD countries. The two countries later joined OECD.
Switzerland in 2021 interpreted that Colombia and Lithuania joining the OECD meant a 5 per cent rate for dividends would apply to the India-Switzerland tax treaty under the MFN clause, rather than 10 per cent as outlined in the agreement.
But post suspension of the MFN status, Switzerland will from January 1, 2025, levy a 10 per cent tax on dividends due to Indian tax residents who claim refunds for Swiss withholding tax and for Swiss tax residents who claim foreign tax credits.
In the statement, the Swiss Finance Department announced suspension of the application of the MFN clause of the protocol to the agreement between the Swiss Confederation and the Republic of India for the avoidance of double taxation with respect to taxes on income.
Switzerland cited a 2023 ruling by Indian Supreme Court in a case relating to Vevey-headquartered Nestle for its decision to withdraw the MFN status.
This means that Switzerland will tax dividends that Indian entities will earn in that country at 10 per cent from January 1, 2025.
According to the statement, in 2021, the Delhi High Court in the Nestle case upheld the applicability of the residual tax rates after taking into account the MFN clause in the double taxation avoidance treaty. However, the Indian Supreme Court, in a decision dated October 19, 2023, reversed the lower court's decision and concluded that, the applicability of MFN clause provided "was not directly applicable in the absence of 'notification' in accordance with Section 90 of the Income Tax Act".
Commenting on the decision of Swiss authority decision, Nangia Andersen M&A Tax Partner Sandeep Jhunjhunwala, said the unilateral suspension of application of the MFN clause under its tax treaty with India, marks a significant shift in bilateral treaty dynamics.
"This suspension may lead to increased tax liabilities for Indian entities operating in Switzerland, highlighting the complexities of navigating international tax treaties in an evolving global landscape," he said.
It also underscores the necessity of aligning treaty partners on the interpretation and application of tax treaty clauses to ensure predictability, equity, and stability in international tax framework, Jhunjhunwala said.
AKM Global, Tax Partner, Amit Maheshwari, said that the main reason behind the decision to withdraw MFN is of reciprocity, which ensures that taxpayers in both countries are treated equally and fairly.
"Swiss authorities announced in August 2021 that based on the MFN clause between Switzerland and India, the tax rate on dividends from qualifying shareholdings would be reduced from 10 per cent to 5 per cent, effective retroactively from July 5, 2018. However, the subsequent Supreme Court ruling in 2023 contradicted the same," Maheshwari said.
Overall, he added that this could impact Swiss investments in India as dividends would be subject to higher withholding now and income accruing on or after January 1, 2025, may be taxed at the rates provided for in the original double taxation treaty between Switzerland and India, regardless of the MFN clause.
JSA Advocates & Solicitors Partner Kumarmanglam Vijay said this would especially impact Indian companies having ODI (overseas direct investment) structures with subsidiaries in Switzerland and will raise the Swiss withholding tax on dividends from 5 per cent to 10 per cent from January 1, 2025.
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TraceX Guard Strengthens National Safety Against Mobile Cyber Threats
India is witnessing a sharp rise in trojanised Android APK scams, as cybercriminals increasingly exploit fake government, banking, LPG, challan, and welfare scheme apps to seize full remote control of victims’ smartphones.
Cybersecurity investigators warn that attackers are now widely deploying Remote Access Trojan (RAT) malware, often powered by leaked builder kits such as CraxsRAT and heavily modified custom payload frameworks. Once installed, these malicious APKs can convert an ordinary Android phone into a fully controlled fraud device, enabling silent surveillance, banking theft, and mass scam propagation.
These malware campaigns are primarily being distributed through WhatsApp, Telegram, SMS phishing links, and fake APK download websites, where users are tricked into installing apps disguised as:
- e-Challan apps
- SBI KYC verification tools
- PM Yojana portals
- mParivahan clones
- LPG booking apps
- fake adult video call apps
As the scale of the threat intensifies, cybersecurity startup TraceX Labs has introduced TraceX Guard, positioning it as a frontline mobile defence platform against APK fraud, RAT infections, QR scams, and malicious permission abuse.
Fear-Based Social Engineering Behind the Surge
According to investigators, these frauds typically begin with panic-driven social engineering messages sent over WhatsApp or Telegram.
Common bait messages include:
- Your traffic challan has been issued
- Your SBI KYC is pending
- PM Yojana verification required
- Your LPG cylinder booking failed
- Your bank account will be blocked
These alerts often include fake challan numbers, vehicle details, Aadhaar-linked references, or forged bank notices, creating a sense of urgency that pushes victims to install the malicious APK without verification.
One of the most dangerous variants currently in circulation is a fake mParivahan-style application, which closely mimics India’s legitimate transport services interface while secretly embedding a hidden RAT payload.
How the Malware Takes Over Smartphones
Once installed, the malicious APK immediately requests dangerous permissions, including:
- Accessibility access
- SMS permissions
- Call logs
- Notifications
- File storage
- Battery optimization exemptions
Security researchers say Accessibility Service abuse remains the most critical attack vector, allowing the malware to silently:
- read screen contents
- detect banking and UPI apps
- auto-click Allow / Confirm / Pay buttons
- capture OTPs
- launch hidden overlays
- navigate banking sessions
- trigger silent fund transfers
Because these actions occur directly on the victim’s trusted device, attackers are often able to bypass traditional fraud detection systems.
Within minutes, victims may lose control over:
- bank balances
- UPI wallets
- Aadhaar and PAN scans
- contact lists
- personal photos and media
- incoming calls
- SMS OTPs
In many cases, the malware also self-propagates by forwarding malicious APK links through the victim’s own WhatsApp groups and Telegram chats, triggering a chain infection effect across trusted social circles.Fake RTO Challan APKs Become the Most Dangerous Variant
Among the most active campaigns, fake RTO challan APK scams have emerged as one of the most financially destructive.
Victims are first lured into paying a ₹1 “verification fee”, after which the malicious app requests highly sensitive information such as:
- card number
- expiry date
- CVV
- UPI PIN
- net banking credentials
- even ATM PINs
Cybersecurity experts stress that no legitimate government payment system ever asks for an ATM PIN inside an app, making this an immediate red flag.
Once payment details are entered, the embedded RAT intercepts OTPs and silently completes unauthorized transactions.
India’s Mobile Fraud Crisis Reaches Critical Levels
Investigators estimate that more than 70% of reported cyber fraud cases in India now originate from mobile devices, with millions of complaints linked to:
- malicious APKs
- phishing URLs
- QR scams
- RAT droppers
- banking session hijacks
- WhatsApp fraud chains
The impact is particularly severe across Tier-2 and Tier-3 regions, where smartphone adoption has expanded faster than awareness around:
- APK sideloading risks
- dangerous permissions
- fake banking overlays
- accessibility abuse
- WhatsApp APK scams
This has effectively turned Android smartphones into the primary battlefield of India’s financial cybercrime ecosystem.
TraceX Guard Introduced as a Real-Time Defence Layer
In response to this rapidly evolving threat landscape, TraceX Labs has launched TraceX Guard, an AI-powered multilingual Android security suite built specifically for India’s APK fraud ecosystem.
The platform offers:
- real-time APK scanning
- malicious permission detection
- hidden app discovery
- RAT behaviour monitoring
- QR & phishing URL safety grading
- OTP and SIM fraud alerts
- Wi-Fi hotspot verification
- ransomware defence
- India-specific scam intelligence feeds
- support for 10+ regional languages
Its offline-first AI architecture allows users to scan threats without uploading personal data, making it especially useful for privacy-conscious users and low-connectivity regions.
TraceX Labs says the system is specifically trained to detect patterns used in:
- fake challan scams
- counterfeit SBI APKs
- PM Yojana malware
- wedding invitation APK attacks
- honey-trap adult apps
- Telegram-based RAT droppers
From Phishing to Malware-Driven Financial Warfare
Cybersecurity analysts say this marks a major shift in India’s digital threat landscape.
What once began as simple phishing links has now evolved into malware-driven financial warfare at scale, where a single infected smartphone can silently compromise:
- families
- WhatsApp groups
- banking accounts
- local communities
- social trust networks
With losses from mobile-first fraud already running into tens of thousands of crores, experts believe the future of cyber defence will increasingly depend on preventive mobile security tools capable of stopping unsafe APKs before installation.
In that battle, TraceX Guard is emerging as one of the most important first lines of defence for India’s digital users.
Download Now : https://play.google.com/store/apps/details?id=com.tracexlabs.guard
