RE: Request to amend an inadvertent inconsistency in Section 194 of the Act 13 April 2020
The income tax framework for Business Trusts (BTs) was first introduced in Finance (No. 2) Act, 2014. Further amendments were undertaken in Finance Act, 2015 and Finance Act, 2016. The key principle that underpinned this framework was to provide for a single level of taxation on income from the underlying assets – this tax was to be assessed on the asset owning SPV’s income; thereafter, such income when distributed by the SPV to the BTs and by the BTs to its unitholders, would not attract any further tax.
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