https://www.taxtmi.com/circulars?id=55429 Explanation 5 to section 9(1)(i) applies to investors in foreign funds whose shares or interests derive substantially from assets located in India, subject to the small investor carve out of Explanation 7 when investors lack management or control and hold below the participation threshold. Master feeder, nominee/distributor, listed fund and sub fund structures are addressed: investors with no control may be excluded, whereas fund level holdings that meet the substantial value test render investor interests taxable. Rule 11UB/11UC govern valuation and apportionment and reporting and withholding obligations remain operative. en-us Wed, 21 Dec 2016 00:00:00 +0530 Thu, 22 Dec 2016 18:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=55429 Explanation 5 to section 9(1)(i) applies to investors in foreign funds whose shares or interests derive substantially from assets located in India, subject to the small investor carve out of Explanation 7 when investors lack management or control and hold below the participation threshold. Master feeder, nominee/distributor, listed fund and sub fund structures are addressed: investors with no control may be excluded, whereas fund level holdings that meet the substantial value test render investor interests taxable. Rule 11UB/11UC govern valuation and apportionment and reporting and withholding obligations remain operative. Circulars Income Tax Wed, 21 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/circulars?id=55429