Tax on foreign institutional investor income: specified fixed rates and carve-outs apply to securities and capital gains. This provision fixes distinct tax rates on income of Foreign Institutional Investors and specified funds from securities and capital gains on their transfer, restricts deductions where gross income is solely taxed securities income, allows deduction after carving out taxed securities income when mixed, disapplies a specified capital gains computation rule for such transfers, and limits application for specified funds to income attributable to units held by non-residents or to qualifying offshore banking unit investment divisions, with key terms defined by notification, statute or Schedule VI.
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Provisions expressly mentioned in the judgment/order text.
Tax on foreign institutional investor income: specified fixed rates and carve-outs apply to securities and capital gains.
This provision fixes distinct tax rates on income of Foreign Institutional Investors and specified funds from securities and capital gains on their transfer, restricts deductions where gross income is solely taxed securities income, allows deduction after carving out taxed securities income when mixed, disapplies a specified capital gains computation rule for such transfers, and limits application for specified funds to income attributable to units held by non-residents or to qualifying offshore banking unit investment divisions, with key terms defined by notification, statute or Schedule VI.
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