<h1>Pre-budget proposals seek broad direct tax reforms: corporate rates, indirect transfer rules, royalties, R&D incentives, and procedural simplification.</h1> The memorandum recommends wide-ranging direct tax and international tax reforms: reduce or remove additional surcharge and rationalise corporate tax/MAT; clarify PE/POEM and indirect transfer rules (including fund exemptions); exclude packaged software and standard telecom facilities from royalty/withholding; restore pass-through treatment for securitisation trusts; expand and extend R&D weighted deductions; simplify and clarify presumptive taxation (44AD/44ADA) including LLP inclusion; strengthen transfer pricing, CbC reporting and GAAR safeguards; and implement procedural reforms to assessment, TDS/TCS, returns, and dispute resolution to reduce litigation and compliance burden.