GlobalFin Services Ltd., a company incorporated in an IFSC (International Financial Services Centre), is engaged exclusively in the business of:…
CA Final · Direct Tax Laws and International Taxation · MTP · September 2025
GlobalFin Services Ltd., a company incorporated in an IFSC (International Financial Services Centre), is engaged exclusively in the business of: Lending in the form of financial leases and providing guarantees, andIntra-group financing and cash management activities as part of Global Treasury operations. It does not accept any public deposits, and it is not registered as a Banking Unit with the IFSC Authority. During the F.Y. 2024-25, GlobalFin Services Ltd. borrows $30 million from its associated enterprise based in the UK and pays interest in foreign currency equivalent to 15 crores. EBIDTA of the company for the P.Y. 2024-25 is 40 crores. What would be amount of interest allowed as deduction while computing Profits and Gains from business or profession in the hands of GlobalFin Services Ltd.? Assume transaction is undertaken at Arm's Length Price.
Suggested Answer and Working Notes:
Correct Answer: Option (C)
15 crores
Topics: Transfer Pricing, Double Taxation Relief, Non-Resident Taxation
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