RULE 126 INCOME-TAX RULES 2026
RULE 126 INCOME-TAX RULES 2026
Conditions and activities for finance company located in any International Financial Services Centre for section 177.
126. (1) For the purposes of section 177(7)(b), the finance company located in any International Financial Services Centre shall only carry out one or more of the following activities, namely:—
| (a) | lending in the form of loans, commitments and guarantees, credit enhancement, securitisation, or financial lease; or | |
| (b) | factoring and forfaiting of receivables; or | |
| (c) | functions of Global or Regional Corporate Treasury Centre such as borrowings, lending, hedging of currency or commodity risk or investments, cash management, structured credit, intra group financing, financial budgeting and similar other such treasury services and activities. |
(2) The interest being paid by such finance company, being the borrower, in respect of any debt issued by a non-resident, shall be in foreign currency.
(3) For the purposes of this rule,—
| (a) | “finance company” means a finance company as defined in regulation 2(1)(e) of the International Financial Services Centres Authority (Finance Company) Regulations, 2021 made under the International Financial Services Centres Authority Act, 2019 (50 of 2019); and | |
| (b) | “International Financial Services Centre” shall have the meaning as assigned to it in section 2(q) of the Special Economic Zones Act, 2005 (28 of 2005). |
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