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of <h1>Section 47(vic) exempts capital gains tax on share transfers from demerged to resulting foreign company if conditions met.</h1> Section 47(vic) of the Income Tax Act addresses the transfer of shares held in an Indian company by a demerged foreign company to a resulting foreign company. This transaction is not considered a transfer for capital gains purposes if it does not attract capital gains tax in the demerged company's country of incorporation. The demerged foreign company is the transferor, and the resulting foreign company is the transferee. At least 75% of the shareholders of the demerged company must become shareholders in the resulting company. The cost in the hands of the transferee is determined by the original acquisition cost.
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