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摘要：In February 2008, the Finance Minister announced some relief whereby a dividend paid to a parent company by its subsidiary would not be liable to DDT, subject to prescribed conditions. Earlier, corporates had a lean structure with one company having many divisions catering to different businesses.

pricing remain somewhat uncertain.

Following the recent change in DDT, many corporates may be considering restructuring their corporate structure so that different business streams have separate Indian operating companies with one common Indian parent. While such types of structuring may help the parent company to unlock shareholder value and should not impose any additional levy of DDT, it should be noted that introducing a new corporate layer at the Indian level will bring the shares in the Indian operating company within the Indian capital gains tax net.

Additionally, even if DDT is not due on dividend payments, there would be an up to 10% cash trap in the Indian operating

Power
Ports &
Airports
Railways
Roads &
Highways
Water
'Undertaking' which generates power
'Undertaking' which transmits or distributes power
'Undertaking' which carries out substantial renovation and modernisation+
Indian companies developing and/or operating & maintaining ports and airports
Applicable also to Inland waterway, Inland port, Navigational channel in the sea
Indian companies developing and/or operating & maintaining rail system
Indian companies developing and/or operating & maintaining roads and highways

'Roads' � includes toll roads, bridges
'Highways' � includes housing or other integral activities
Includes water supply project, water treatment system, irrigation project, sanitation and sewerage system or solid waste management system
10 consecutive years out of 15 years
10 consecutive years out of 15 years
10 consecutive years out of 20 years
10 consecutive years out of 20 years
10 consecutive years out of 20 years
All the above should commence (+complete) before March 31, 2010
'New' infrastructure facility
Agreement with government/ statutory body
'New' infrastructure facility
Agreement with government/ statutory body
'New' infrastructure facility
Agreement with government/ statutory body
'New' infrastructure facility
Agreement with government/statutory body

Infrastructure in India: A vast land of construction opportunity companies, as in accordance with Indian regulatory provisions, only 90% of a company's distributable reserves may be paid as dividends.

Therefore, a construction company working on multiple projects in India should consider all relevant factors bespoke to their requirements before structuring their operations. International tax considerations Effective tax structuring into India is vital as this impacts on how attractive a project is to target investors and has a direct influence on the net internal rate of return. https://www.51lunwen.org/cb/ It is therefore particularly important that international investment opportunities are structured appropriately to take into consideration tax, accounting, regulatory and legal aspects. We have outlined below some of the key areas to consider.

Entry and exit strategy Holding company location � Appropriate planning in respect of a holding company jurisdiction is necessary to minimise Indian withholding tax and Indian capital gains on the sale of shares in Indian companies. Financing � In order to introduce debt into India, there are various issues that need to be considered such as the Indian External Commercial Borrowings rules, withholding tax issues on distri本论文由英语论文网提供整理，提供论文代写，英语论文代写，代写论文，代写英语论文，代写留学生论文，代写英文论文，留学生论文代写相关核心关键词搜索。