We can say that anybody and everybody is affected by the element of Gaar in a one way or other in India. As a net result we may see a number of Corporations undertaking the restructuring of the salaries of employees as they have to make sure that a taxmen do not comes to a conclusion that these salaries were structured to save tax.
The major chunk of effects is going to be seen by Foreign institutional investors (FIIs), who invest through countries such as Mauritius to exploit bilateral tax treaties will be affected after GAAR comes into force.
FIIs are worried because they are under a state of fear that on the implementation of the GAAR, they may be forced to pay capital gains tax for their investment in Indian equities. However they must realise that Indian tax man are only gunning for those who are deliberately undertaking actions to avoid payment of tax as In India, the courts have ruled that saving of taxes through permissible instruments of tax planning is legitimate. But tax avoidance is illegal and they have to just safeguard against the same and their interest will be always protected.