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There is concern that a portion of the dividend to be declared by companies operating out of the International Financial Services Centre (IFSC) could come under the tax net.The central government had announced various tax sops for new businesses engaging in financial services at IFSC, set up at GIFT City in Gujarat. Among these, waiver of dividend distribution tax (DDT) on profits distributed by IFSC companies was considered a major relief, as it would help them to repatriate profits without additional cost to the business.However, the waiver has been provided for dividend distributions made by IFSC companies only from current income. The present company law provisions, which apply to companies set up at the IFSC, permit declaration of dividends out of accumulated profits. Given these, companies could potentially bifurcate the amount of dividends paid out of current income and accumulated profits. To the extent dividends are declared out of the latter, they will have to pay DDT at ...