Pass-through taxation treats investor income from securitisation trusts as directly accruing to investors for tax. Income from securitisation trusts is taxed on a pass-through basis: income received by or accruing to an investor from investments in a securitisation trust is chargeable as if the investor held the underlying investments directly; such income is deemed to be of the same nature and proportion in the investor's hands. Unpaid trust income is deemed credited to the investor on the last day of the tax year in the proportion they would have been entitled to receive. The trust and the payer must provide prescribed statements to the taxpayer and tax authority. Income included on account of accrual is not taxed again when actually paid.
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.
Pass-through taxation treats investor income from securitisation trusts as directly accruing to investors for tax.
Income from securitisation trusts is taxed on a pass-through basis: income received by or accruing to an investor from investments in a securitisation trust is chargeable as if the investor held the underlying investments directly; such income is deemed to be of the same nature and proportion in the investor's hands. Unpaid trust income is deemed credited to the investor on the last day of the tax year in the proportion they would have been entitled to receive. The trust and the payer must provide prescribed statements to the taxpayer and tax authority. Income included on account of accrual is not taxed again when actually paid.
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