Taxation of offshore funds: special tax rates apply to income from foreign currency purchased units and related capital gains. The provision sets a special tax regime for an overseas financial organisation (Offshore Fund) that receives income from units purchased in foreign currency or long term capital gains on their transfer, applying specified fixed tax rates to those income categories. Deductions are disallowed if gross total income consists only of such income; where such income is part of broader income it is first excluded from gross total income and Chapter VIII deductions are then computed on the reduced gross total income. Key definitions and approval requirements for qualifying arrangements are provided.
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.
Taxation of offshore funds: special tax rates apply to income from foreign currency purchased units and related capital gains.
The provision sets a special tax regime for an overseas financial organisation (Offshore Fund) that receives income from units purchased in foreign currency or long term capital gains on their transfer, applying specified fixed tax rates to those income categories. Deductions are disallowed if gross total income consists only of such income; where such income is part of broader income it is first excluded from gross total income and Chapter VIII deductions are then computed on the reduced gross total income. Key definitions and approval requirements for qualifying arrangements are provided.
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