During the financial year 2024-25, MNO International Singapore (a company incorporated in Singapore) held shares carrying voting power of 25% in XYZ…

CA Final · Direct Tax Laws and International Taxation · MTP · May 2026
During the financial year 2024-25, MNO International Singapore (a company incorporated in Singapore) held shares carrying voting power of 25% in XYZ (India) Ltd. (an Indian Company). XYZ (India) Ltd., who is a wholly owned subsidiary of PQR International Singapore, also held shares carrying voting power of 36% in PQR (India) Ltd. PQR (India) Ltd is engaged in manufacturing of industrial chemicals and for such manufacturing, it is wholly dependent on the technical know-how provided by PQR International Singapore. During the financial year, royalty of 25 Crores was paid by PQR (India) Ltd. to PQR International Singapore. Considering the above facts, which of the following statements is correct:-
(A) XYZ (India) Ltd is only associated enterprise of PQR International Singapore.
(B) XYZ (India) Ltd and PQR (India) Ltd, both are associated enterprise of PQR International Singapore.
(C) Neither XYZ (India) Ltd, nor PQR (India) Ltd is associated enterprise of PQR International Singapore.
(D) PQR (India) Ltd is only associated enterprise of PQR International Singapore.

Suggested Answer and Working Notes:

Correct Answer: Option (B)

XYZ (India) Ltd and PQR (India) Ltd, both are associated enterprise of PQR International Singapore.

Topics: Transfer Pricing, Double Taxation Relief, Non-Resident Taxation

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