Deemed situs of foreign shares: transfers tied to Indian assets can attract Indian tax treatment on gains. Income from transfer of foreign shares or interests is taxable in India if those shares are deemed to derive their value substantially from assets located in India, where on the specified date Indian assets exceed ten crore rupees and at least fifty per cent of total assets; valuation, specified date and accounting period are prescribed. No income is deemed to accrue in India where, in the preceding twelve months, the transferor (alone or with associated enterprises) neither exercises management/control nor holds voting power, share capital or interest exceeding five per cent in the direct holder of Indian assets. Interest paid by an Indian permanent establishment of a non-resident bank to its foreign head office or other parts is deemed to accrue in India and the permanent establishment is treated as a separate taxable person.