Tax rate and structural reforms clarified: residency, indirect transfer, REIT/InvIT, AIF pass through and fund manager rules updated. The Finance Act, 2015 prescribes income tax rates and TDS mechanics for 2015 16 and enacts extensive amendments: company residency uses place of effective management; indirect transfer rules are restructured with value thresholds, valuation dates, proportional taxation and reporting obligations; banks' PE interest payments to head offices are taxable in India; REITs/InvITs and certain GDRs and AIFs receive specialised tax regimes; fund manager activities in India are generally not a business connection for eligible offshore funds subject to conditions; GAAR is deferred and wealth tax abolished.
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Tax rate and structural reforms clarified: residency, indirect transfer, REIT/InvIT, AIF pass through and fund manager rules updated.
The Finance Act, 2015 prescribes income tax rates and TDS mechanics for 2015 16 and enacts extensive amendments: company residency uses place of effective management; indirect transfer rules are restructured with value thresholds, valuation dates, proportional taxation and reporting obligations; banks' PE interest payments to head offices are taxable in India; REITs/InvITs and certain GDRs and AIFs receive specialised tax regimes; fund manager activities in India are generally not a business connection for eligible offshore funds subject to conditions; GAAR is deferred and wealth tax abolished.
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