indian shares

No capital gains in a business reorganization if consideration not determinable. Transfer pricing law does not apply if there is no income

The applicant, a USA company, held shares in an Indian company. As part of a bankruptcy reorganization process, the shares in the Indian company together with other non-Indian assets & liabilities were transferred to other USA companies. The liabilities taken over were more than the assets. The agreement provided that the transfer of the shares was without consideration. The AAR had to consider (i) whether the liabilities of the transferor taken over by the transferee co..
Full Article
Copyright © TaxGuru 2011. All Rights Reserved.
About Us - Advertise - Privacy Policy - Back to top