Relocation of foreign fund assets now tax-neutral when transferred to India resultant funds in exchange for proportionate interests. Amendments treat transfers in a relocation as not constituting transfer: (i) transfers of capital assets by an 'original fund' to a 'resultant fund' and (ii) transfers by shareholders/unit holders of interests in the original fund in consideration for interests in the resultant fund. Definitions specify an original fund as a non-resident, investor-protection-regulated foreign fund resident in or established in treaty/ notified jurisdictions; relocation means asset transfer to a resultant fund in exchange for proportional interests; resultant fund must be India-established, AIF-registered and located in an IFSC.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Relocation of foreign fund assets now tax-neutral when transferred to India resultant funds in exchange for proportionate interests.
Amendments treat transfers in a relocation as not constituting transfer: (i) transfers of capital assets by an "original fund" to a "resultant fund" and (ii) transfers by shareholders/unit holders of interests in the original fund in consideration for interests in the resultant fund. Definitions specify an original fund as a non-resident, investor-protection-regulated foreign fund resident in or established in treaty/ notified jurisdictions; relocation means asset transfer to a resultant fund in exchange for proportional interests; resultant fund must be India-established, AIF-registered and located in an IFSC.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.