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TMI BlogCOMPUTATION OF INCOME ATTRIBUTABLE TO A CONTROLLED FOREIGN COMPANYX X X X Extracts X X X X X X X X Extracts X X X X ..... 100 x C/D Where A = specified income of the Controlled Foreign Company as computed under paragraph 4; B = percentage of— (i) value of capital, (ii) voting share or interest, whichever is higher, held by the assessee, directly or indirectly, in the Controlled Foreign Company; C = number of days out of D, the voting shares or capital or interest has been held by the assessee in the Controlled Foreign Company; D = number of days the company remained as a Controlled Foreign Company during the accounting period; 4. The specified income of the Controlled Foreign Company shall be computed in accordance with the formula— (A + B - C - D) x E/F Where A = net profit as per profit and loss account of the Controlled Foreign Company for the accounting pe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ; (v) the specified income of the company determined in accordance with the provisions of paragraph 4 exceeds twenty-five lakh rupees; (b) one or more persons resident in India shall be said to exercise control over the company if — (i) such persons, individually or collectively possess or are entitled to acquire directly or indirectly shares carrying not less than fifty per cent. of the voting power or not less than fifty per cent. capital of the company; (ii) such persons, individually or collectively are entitled to secure that not less than fifty per cent. of income or asset of the company shall be applied directly or indirectly for their benefit; (iii) such persons, individually or collectively, exercise dominant influence on the compa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ounting period resident in a territory with a lower rate of taxation; (d) "territory with a lower rate of taxation" means a country or a territory outside India in which the amount of tax paid under the law of that country or territory in respect of profits of a company that accrue in any accounting period, is less than one-half of the corresponding tax payable on those profits computed under this Code, as if the said company was a domestic company; (e) a company shall be deemed to be engaged in active trade or business if and only if — (i) it actively participates in industrial, commercial or financial undertakings through employees or other personnel in the economic life of the territory of which it is resident for tax purposes; and (ii) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of its incorporation and end with the 31st day of March or such other day, as the case may be, following the date of such incorporation, and the later accounting period shall be the successive periods of twelve months. (4) If the company ceases to exist before the end of accounting period, as mentioned in sub-paragraphs (1), (2) and (3), the accounting period shall end immediately before the company ceases to exist. 7. A resident assessee shall furnish the details of its investment and interest in any entity outside India in such form and manner as may be prescribed. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement - taxmanagementind ..... X X X X Extracts X X X X X X X X Extracts X X X X
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