Income deemed to accrue in India defines source rules, business connection and significant economic presence for tax allocation. Income deemed to accrue or arise in India covers income from any asset or source in India, any property in India, any business connection in India, and transfers of capital assets situated in India. It specifically deems salaries for services in India, dividends of Indian companies, interest, royalties and fees for technical services to be Indian-sourced under prescribed payer, use and attribution rules. The clause expands business connection to include business carried out in India and significant economic presence, attributes digital-economy income to presence in India, and sets tests for foreign shares deriving value from Indian assets, with specified exemptions and an eligible investment fund carve-out.
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.
Income deemed to accrue in India defines source rules, business connection and significant economic presence for tax allocation.
Income deemed to accrue or arise in India covers income from any asset or source in India, any property in India, any business connection in India, and transfers of capital assets situated in India. It specifically deems salaries for services in India, dividends of Indian companies, interest, royalties and fees for technical services to be Indian-sourced under prescribed payer, use and attribution rules. The clause expands business connection to include business carried out in India and significant economic presence, attributes digital-economy income to presence in India, and sets tests for foreign shares deriving value from Indian assets, with specified exemptions and an eligible investment fund carve-out.
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