TaxTMI 
TaxTMI 
Wholly Owned Subsidiary
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....holly Owned Subsidiary<br> Query (Issue) Started By: - KR Ramesh Dated:- 22-7-2011 Last Reply Date:- 28-7-2011 Income Tax<br>Got 3 Replies<br>Income Tax<br>Hi, I have a query on the Corporate Tax Ra....
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....te of a Wholly Owned Subsidiary of a Foreign Company. A company is registered in India as a Private Limited Company, 100% equity is being held by the foreign entitiy. Query , For Income Tax Purpose....
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.... 1) would this be treated as a foreign company and taxed @40% 2) or it would be treated as a domestic company and taxed @ 30% Please advice the reasons for the answer quoting the reference of the c....
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....onstitution if any Many thanks Regards Ramesh Reply By MOHAN S: The Reply: Dear Mr.Ramesh, Kindly read the definition of a "Foreign Company" and "domestic company" under Income Tax Act 1961. The....
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.... answer is clearly available there. Reply By Bakul Gandhi: The Reply: Generally, a subsidiary company is a legal entity distinct from the holding company and will be taxed at 30% as Domestic Company....
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..... However, if the subsidiary company is construed as PE-Permanent Establishment- of holding company in terms of relevant Double Taxation Avoidance Agreement, it will be taxed at 40%. whether subsii....
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....diary is PE or not - refer to P.No 8 of 1995 223 ITR 416 (AAR) Reply By KR Ramesh: The Reply: Dear Mr. Gandhi, Many thanks for giving the direction, Indeed it is highly appreciated. Kind Regards ....
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.... Ramesh<br> Discussion Forum - Knowledge Sharing ....