Consortium agreement

Tax queries 513 views 1 replies

Dear Sir/Madam

Our company is going to enter into consortium agreement.
May I kindly request you to provide me any Income tax related issue in this structure

Regards
Manish Mehta

Replies (1)

In case your company is in consortium agreement with a foreign company, The whole JV might be considered as a Resident AOP for taxation.

In case of Linde AG in AAR No 962 of 2010 dated 20.03.2012, the Authority for Advance Ruling AAR has taken a view that consortium agreement will result in formation of an AOP for tax purposes in India.

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