The Ministry of Finance has issued a Notification dated 1.11.2013 notifying Cyprus as a "notified jurisdictional area" u/s 94A of the Income-tax Act, 1961.
The consequences of the Notification are draconian and are broadly the following:
(i) All transactions with a person in Cyprus will have to meet the rigors of transfer pricing;
(ii) A deduction in respect of any payment made to any financial institution in Cyrus and deduction in respect of any other expenditure or allowance arising from the transaction with a person located in Cyprus is subject to specific conditions;
(iii) Sum received from a person located in Cyprus is deemed to be the income of the assessee unless the assessee satisfactorily explains the source of such money in the hands of the payer;
(iv) Payments to persons located in Cyprus is liable for TDS at 30 per cent
09 November 2013
CBDT on Cyprus
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