IND LTD in INDIA(wholly owned subsidiary company) of F LTD (FOREIGN COUNTRY). FOREIGN country tax laws treat IND LTD as Transperant company and INDIAN Tax law treats IND LTD as opeque company. Question is whether in FOREIGN COUNTRY ALL THE INCOME OF IND LTD ARISING IN INDIA WILL BE TAXABLE IN THE HANDS OF F LTD AND WHETHER EXPENDITURE OF IND LTD WILL BE ALLOWED IN THE HANDS OF F LTD ??
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Hybrid mismatch arrangement
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Income of IND LTD will be taxable in the hands of IND LTD
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