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The Central Board of Direct Taxes (CBDT), under the Ministry of Finance, Government of India, recently issued a press release on September 26, 2023, announcing significant changes to Rule 11UA with respect to the “ANGEL TAX.” These changes come in response to amendments introduced by the Finance Act of 2023. The amendments primarily concern the taxation of consideration received from non-residents for the issuance of shares by unlisted companies under Section 56(2) (viib) of the Income-tax Act, 1961.
Here’s a detailed explanation of the key highlights and implications of the CBDT’s notification:
In summary, the CBDT’s notification regarding changes to Rule 11UA reflects the Indian government’s commitment to creating a more equitable and transparent tax framework for both resident and non-resident investors in unlisted companies. The introduction of additional valuation methods and the safe harbour provision are significant steps towards achieving these objectives.
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