https://www.taxtmi.com/circulars?id=53279 The circular clarifies that Explanation 5 applies where a transaction in shares or interests in a foreign entity effects the direct or indirect transfer of underlying assets located in India, thereby creating an Indian economic nexus and rendering gains taxable in India. It further clarifies that declaration and payment of dividends by a foreign company, even if the shares derive substantial value from Indian assets, do not constitute such a transfer and therefore are not deemed to accrue or arise in India under the Explanation. en-us Thu, 26 Mar 2015 00:00:00 +0530 Tue, 20 Feb 2024 17:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=53279 The circular clarifies that Explanation 5 applies where a transaction in shares or interests in a foreign entity effects the direct or indirect transfer of underlying assets located in India, thereby creating an Indian economic nexus and rendering gains taxable in India. It further clarifies that declaration and payment of dividends by a foreign company, even if the shares derive substantial value from Indian assets, do not constitute such a transfer and therefore are not deemed to accrue or arise in India under the Explanation. Circulars Income Tax Thu, 26 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/circulars?id=53279