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CBDT amends definition of intra-group loans for safe harbour

Posted Date : 21-Dec-2023 , 08:33:03 am | Posted By CASANSAAR print Print
In line with new business practices, the Union finance ministry has amended the definition of intra-group loans and has removed the condition of sourcing the loan in Indian rupees. It has also amended the circumstances when they can be treated as safe harbour. 

The Central Board of Direct Taxes has notified amendments to Rule 10TA and Rule 10TD of the Income Tax Rules that relate to safe harbour provisions for international transactions, with effect from April 1, 2024. 

It has amended the definition of ‘intra-group loan’ to mean a loan advanced to an associated enterprise being a non-resident, where the loan is not advanced by an enterprise, being a financial company including a bank or a financial institution or an enterprise engaged in lending or borrowing in the normal course of business; and does not include credit line or any other loan facility which has no fixed term for repayment. 

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