Amendments in Rule 10TA and 10TD of Safe Harbour Rules for International Transactions - Income-tax (Twenty-Ninth Amendment) Rules, 2023 - 104/2023 - Income Tax

Safe harbour for intra-group loan interest updated: new reference rate benchmarks and credit rating spread tiers ensure rate compliance.

Amendments redefine intra-group loan to exclude loans from financial institutions and open-ended facilities, revise treatment of income and loss on transfer of non-depreciable assets, and replace the foreign currency intra-group loan safe harbour with a tiered interest schedule. The schedule requires interest not less than the relevant currency reference rate as of the prescribed date plus credit rating based spreads that vary by aggregate loan exposure, and an Explanation specifies the benchmark reference rates and rules for determining applicable credit ratings.