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    <title>Cyprus Notified as a notified Jurisdictional Area Under Section 94a of the Income-Tax Act, 1961 ; All Parties to the Transaction with a Person in Cyprus shall be Treated as Associated Enterprises and the Transaction shall be Treated as an International Transaction Resulting in Application of Transfer-Pricing Regulations Including Maintenance of Documentations</title>
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    <description>Designation of Cyprus as a notified jurisdictional area under Section 94A causes transactions with persons in Cyprus to be treated as international transactions between associated enterprises, subject to transfer pricing regulations and mandatory documentation. Deductions for payments to Cypriot financial institutions require authorization for information access; other deductions require prescribed documentation. Receipts from Cypriot persons must be satisfactorily explained as to source or beneficial ownership or be deemed income, and payments to Cyprus are subject to withholding tax at the prescribed rate.</description>
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      <description>Designation of Cyprus as a notified jurisdictional area under Section 94A causes transactions with persons in Cyprus to be treated as international transactions between associated enterprises, subject to transfer pricing regulations and mandatory documentation. Deductions for payments to Cypriot financial institutions require authorization for information access; other deductions require prescribed documentation. Receipts from Cypriot persons must be satisfactorily explained as to source or beneficial ownership or be deemed income, and payments to Cyprus are subject to withholding tax at the prescribed rate.</description>
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