Dividend distribution tax base reduction for subsidiary dividends and pension trust payouts under the domestic dividend regime. Dividend distributed by a domestic holding company is reduced by dividends received during the financial year from a domestic subsidiary that has already paid dividend distribution tax, and by dividends received from a foreign subsidiary on which tax is payable by the holding company under the foreign dividend tax provision. The reduction prevents the same dividend amount from being taxed at multiple corporate levels. Dividend paid to any person for, or on behalf of, the New Pension System Trust is also excluded from the dividend distribution tax base.
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Provisions expressly mentioned in the judgment/order text.
Dividend distribution tax base reduction for subsidiary dividends and pension trust payouts under the domestic dividend regime.
Dividend distributed by a domestic holding company is reduced by dividends received during the financial year from a domestic subsidiary that has already paid dividend distribution tax, and by dividends received from a foreign subsidiary on which tax is payable by the holding company under the foreign dividend tax provision. The reduction prevents the same dividend amount from being taxed at multiple corporate levels. Dividend paid to any person for, or on behalf of, the New Pension System Trust is also excluded from the dividend distribution tax base.
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