[34830]
January 26, 2023
TO: ICI MembersICI Global Members
Global Regulated Funds Committee
Global Regulated Funds Committee - Asia
Global Tax Committee
Management Company Tax Subcommittee
Tax Committee SUBJECTS: International/Global
Tax RE: India: ICI Global Submits Letter Re Indian 2023 Budget Tax Issues
ICI Global submitted the attached letter to the Indian Government for consideration as they develop the 2023 Union Budget. The letter describes tax issues and proposes recommendations to address the global regulated fund industry's outstanding tax issues.
Many of these issues have been raised in prior ICI Global submissions and include:
1) Tax Rate for Interest Income from Specific Investments
2) Competitive Tax Rates and Tax Parity Across Similar Assets
3) Processing Errors and Rectification Orders
4) Tax Status of Foreign Regulated Funds
5) Reorganizations Involving Business Trusts and Debt Funds/Multi-Asset Funds
6) Clarification on Hierarchy of Capital Loss Offsets
7) Off-Market Transfers of Listed Securities
8) Tax Re-assessment Period, Audit Issues and Dispute Resolution
9) India-Based Fund Manager Regime
10) Accept Electronically Signed Documents
11) Significant Economic Presence Provisions
The submission includes annexures with detailed legal analysis and draft legislation to implement the recommendations. There will be a members-only zoom meeting on Monday, February 13, 2023 at 11:00 am (ET) to discuss India's 2023 Union Budget.
Katie Sunderland
Assistant General Counsel