The proposed amendments to income deemed to accrue or arise in ...

Proposed Tax Bill Expands Business Connection Rules and Digital Economy Taxation Under Sections 9 and 9A

February 26, 2025

Notes     Bill

The proposed amendments to income deemed to accrue or arise in India under the Income Tax Bill, 2025, introduce comprehensive modifications to existing provisions under ss 9 and 9A of ITA 1961. Key changes include expanded definition of business connection incorporating significant economic presence, detailed framework for digital economy taxation, and modified investment fund management provisions. The amendments align with OECD BEPS guidelines while introducing specific provisions for online advertising, data monetization, and digital services targeting Indian market. The revised framework modernizes India's international taxation approach, particularly addressing digital economy challenges. Notable implications include reassessment requirements for businesses' digital presence, enhanced scope of taxable income for non-residents, and modified compliance obligations for fund managers under the new regulatory structure.

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