The Finance Act, 1976--Explanatory notes on provisions relating to direct taxes
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Taxation of cross-border royalties and technical fees: new source and withholding rules increase gross-basis taxation and limit deductions.
The Finance Act, 1976 revises withholding and source rules and prescribes flat gross basis taxation for dividends, royalties and fees for technical services received by foreign companies, limits deductible expenses for such receipts, broadens the statutory source rules for interest, royalty and technical service payments to deem specified payments to accrue in India, and introduces an investment allowance with conditions and reserve requirements together with mechanisms for withdrawal where conditions are breached.