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of <h1>Securitisation Trusts Get Tax Neutrality Boost: Investors Taxed Directly Under New Clause 221 Framework</h1> Legal Analysis Summary:The document examines Clause 221 of the Income Tax Bill, 2025, which establishes a pass-through taxation regime for securitisation trusts. The provision ensures tax neutrality by taxing investors as if they directly held the underlying assets, preserving income character and preventing double taxation. Key features include accrual-based taxation, mandatory reporting requirements, and specific definitions for investors and trusts. The clause largely maintains the framework of the previous Section 115TCA, providing continuity in tax treatment for securitisation financial instruments while aligning with regulatory guidelines from financial sector authorities.
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