Income deemed to accrue in India: broad sourcing rules capture assets, business connections and significant economic presence.

Income is deemed to accrue or arise in India if derived from any asset or source in India, property in India, a business connection in India, or the transfer of a capital asset situated in India. Interest, royalty and fees for technical services payable by the Government, residents or non-residents are treated as Indian-sourced unless used for activities or income generation outside India. Business connection includes habitual agents and a prescribed significant economic presence; only income reasonably attributable to Indian operations or such presence is taxable. Shares of foreign entities may be treated as situated in India where value substantially derives from Indian assets, subject to specified thresholds and carve-outs.

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