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<h1>Foreign Institutional Investors Face New Tax Regime with Graduated Rates and Comprehensive Income Classification Under Clause 210</h1> Legal Analysis Summary:The document examines Clause 210 of the Income Tax Bill, 2025, which introduces a comprehensive taxation framework for foreign institutional investors and specified funds. The provision establishes differentiated tax rates for various income categories, ranging from 10-30%, with specific focus on income from securities and capital gains. Key objectives include harmonizing tax computation methods, facilitating specified fund operations, ensuring international best practices, and preventing tax arbitrage. The clause provides clear guidelines for income attribution, disallows certain deductions, and aims to create a transparent, competitive investment environment while maintaining robust compliance mechanisms.
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