But the government postponed it by a year, saying it wanted to give more time to the industry to adjust to the new system.
CFC and GAAR are two key highlights of the proposed DTC and are not there in the existing I-T Act.
The DTC Bill has proposed to introduce CFC rules in India for the first time.
The rules will allow authorities to tax foreign companies controlled by residents which defer payment of tax.
At present, taxing these companies gets deferred as companies delay the payment of dividends.
Foreign companies controlled by residents are taxed in the hands of the Indian company only when distributed in the form of dividends.
GAAR and CFC details will be provided separately in the rules to be framed by the finance ministry.
Thin capitalisation rules, which help tax authorities reclassify some of the interest paid on debt as dividend and deduct tax on it, may also come under GAAR.
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