Vivek Jalan
Quick Summary
The CBDT vide Notification No. 104/2023 dated December 19, 2023, issued the Income-tax (Twenty-Ninth Amendment) Rules, 2023, amending Rules 10TA and 10TD of the Income Tax Rules, 1962 (the IT Rules). The amendments aim to redefine intra-group loans and specify conditions under which they fall within
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FAQ :
The CBDT has redefined intra-group loans to include loans advanced to 'Associate Enterprises' rather than just wholly-owned subsidiaries, and the requirement for loans to be sourced in Indian Rupees has been removed.
These amendments are set to come into effect from April 1, 2024.
Rule 10TD has been amended to replace the conditions for safe harbour for intra-group loans denominated in foreign currency, and the specific mention of 'CRISIL' credit rating has been omitted.
These changes are intended to provide greater clarity and certainty for taxpayers, reduce potential disputes with tax authorities regarding transfer pricing, and promote the ease of doing business for multinational companies operating in India.
Taxpayers may need to review and potentially restructure their existing loans to ensure compliance with the new definition and safe harbour conditions.
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