TaxTMI 
TaxTMI 
TaxTMI 
Limitation of Interest Deduction - Section 94B
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....se like guarantee commission etc.) claimed by an Indian company or a permanent establishment of a Foreign company in India in respect of any debt issued by a non-resident being an associated enterprises shall not deductible in computation of income under the "Profits & Gains of business or profession" to the extent that it arises from excess interest. Limit of Interest: Provision of this section ....
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....wing has been excluded from the applicability of the provisions of section 94B(1) - * Interest paid in respect of debt issued by a lender which is PE in India of Non-resident, being a person engaged in the business of banking. [Section 94B(1A) ] * an Indian company or permanent establishment of a foreign company which is engaged in the business of banking or insurance [or a Finance Company loc....
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....al Government and by notification in the Official Gazette, specify. Calculation of Excess Interest [ Section 94B(2) ] * Total Interest paid or payable in excess of 30% of its earnings before interest, taxes, depreciation and amortization (EBIDTA) of the borrower in the previous year or * Interest paid or payable to Associated Enterprises whichever is LOWER. Carry Forward of Excess Interest....
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....nal Financial Services Centres Authority (Finance Company) Regulations, 2021 made under the International Financial Services Centres Authority Act, 2019 and which satisfies such conditions and carries on such activities, as may be prescribed; (1) For the purposes of section 94B(5)(iv), the Finance Company located in any International Financial Services Centre shall only carry out one or more of t....