On 4 January 2024, India’s Central Board of Direct Taxes (CBDT) issued Notification No. 4/2024 as per the provisions of Section 10, Clause 4G, of the Income Tax Act, 1961. This notification specifically addresses entities who are not residents and are involved in investment activities via a contract with a capital market intermediary, specifically emphasizing units within an International Financial Services Centre (IFSC). The financial products eligible for this exemption are defined in the International Financial Services Centres Authority Act, 2019 and include securities, insurance contracts, deposits, credit arrangements, certain foreign currency contracts, and any other products or instruments notified by the Central Government. The category of capital market intermediaries encompasses merchant bankers, lead merchant bankers or lead managers, registrars, share transfer agents (RTA), underwriters, debenture trustees, bankers to an issue, portfolio managers, as well as stockbrokers and sub-brokers.
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