Clarifications on Declaration of Cyprus As A Notified Jurisdictional Area - Special Measures in Respect of Transactions With Persons Located in Notified Jurisdictional Area Under Section 94A of The Income Tax Act, 1961.
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Notified jurisdictional area designation triggers transfer pricing treatment and strict documentation, withholding, and disclosure obligations. Notification as a notified jurisdictional area due to lack of effective information exchange causes transactions with persons in that area to be treated as between associated enterprises and as international transactions, invoking transfer-pricing regulations and documentation obligations. Deductions for payments to financial institutions are disallowed without an authorization permitting information access; other deductions require prescribed documentation. Receipts from such persons must be explained as to source and beneficial ownership or be deemed income, and payments to persons in the jurisdiction are subject to a statutory withholding tax.
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.
Notified jurisdictional area designation triggers transfer pricing treatment and strict documentation, withholding, and disclosure obligations.
Notification as a notified jurisdictional area due to lack of effective information exchange causes transactions with persons in that area to be treated as between associated enterprises and as international transactions, invoking transfer-pricing regulations and documentation obligations. Deductions for payments to financial institutions are disallowed without an authorization permitting information access; other deductions require prescribed documentation. Receipts from such persons must be explained as to source and beneficial ownership or be deemed income, and payments to persons in the jurisdiction are subject to a statutory withholding tax.
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