Subsidiaries

15/06/1988

Query

Would a situation where a subsidiary takes title to the goods manufactured by the qualifying company and then sells them on or "lease-on" to customers, be regarded as rendering of services to ensure that the subsidiary would be a qualifying one?

Decision

Yes

Income Tax

Section 507 (1), Taxes Consolidation Act, 1997

Origin: Direct Taxes International and Administration

File ref:2344/85




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