Act RulesIncome Tax
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Business connection safe harbour for non-resident funds: compliance thresholds determine Indian tax nexus exclusion.
The Schedule establishes a safe harbour whereby certain non-resident investment funds and eligible fund managers will not constitute a business connection in India if they satisfy exhaustive investor-composition, concentration, corpus, independence, non-control, prohibited-associate-investment and arm's-length remuneration conditions, with specified carve-outs, transitional reliefs, registration requirements under prescribed securities-regulator frameworks, and filing and record keeping obligations to substantiate compliance.