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AN OVERVIEW OF DIRECT TAXES CODE BILL
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AN OVERVIEW OF DIRECT TAXES CODE
BILL
AUTHORED BY- AYUSH PATIDAR &
SNEHA SHARMA
I.
INTRODUCTION
1. India's direct tax system needed
reform and simplification, hence the Direct Tax Code (DTC) Bill, 2010, was an
important legislative initiative. The Direct Tax Code, a single, comprehensive
piece of legislation, was intended to replace and modernise the current tax
laws, mainly the Income Tax Act of 1961 and the Wealth-tax Act of 1957.[1]
2. The Standing Committee on Finance [2]has
agreed the Chairman permission to present this 49th Report on "the Direct
Taxes Code Bill, 2010.” On September 9, 2010, the Speaker of the Lok Sabha,
acting in accordance with Rule 331E of the Rules of Procedure and Conduct of Business in the Lok
Sabha, referred the Direct Taxes Code Bill, 2010, which had been tabled in the
Lok Sabha on August 30th, to the Committee for review and a report thereon.
3. The Committee overheard oral
testimony from the Ministry of Finance's (Department of Revenue) official during
its meetings on November 18, 2010, and November 11, 2011. The Committee
received the opinions of the Confederation of Indian Industries (CII) and
Institute of Chartered Accountants of India (ICAI) representatives at their conference
on January 19, 2011, in which it was held. Representatives from NASSCOM, the
Export Promotion Council for EOUs and SEZs, Earnest & Young Private
Limited, KPMG, the Coalition of International Taxation in India, and the
Cellular Operators Association of India shared their perspectives with the
Committee during the meeting on October 17, 2011.[3]
4. Several stakeholders' thoughts were
also heard by the Committee during the study These stakeholders comprised the
Bombay Chambers of Commerce, Bombay chartered Accountants Society, General
Insurance Council and Life Insurance Council, Indian Merchant's Chamber, Madras
Chambers of Commerce and Industry, Income Tax Appellate Tribunal Bar
Association, Mumbai, Saifee Hospital Trust, National Sea Farers Association,
Container Shipping Lines Associations, All India Federation of Tax
Practitioners, e When the study group visited Srinagar on the 15th and 16th of
June 2011, they also spoke with the Income Tax Department about a few tax
administration-related issues.[4]
5. The Committee examined the draft
Report on "the Direct Taxes Code Bill, 2010" at its meetings on
February 10, February 17, and February 24, 2012, and adopted it at its meeting
on March 2, 2012. The Committee would like to thank the Ministry of Finance
(Department of Revenue) staff members involved with the Bill for their
cooperation as well as all the groups and experts for their insightful comments
on the Bill.[5]
Ø Need for complete review of the prevailing
Income Tax and Wealth tax Acts[6]
1. The Committee desired to know whether
it was compulsory to conduct a thorough review of the contemporary Income Tax
and Wealth Tax Acts. The Ministry of Finance (Department of Revenue) responded
in writing. stated as follows:
2. The Income-tax Act of 1961 has
undergone a number of modifications in the fifty years after its passage. It
has endured significant revisions, not by amendment, less than thirty-four
times. Further Acts to the Amendments carried out by means of the yearly
Finance Acts. These variations were required by policy adjustments brought about
by the fluctuating nature of the economy, the sophistication of commerce, the
rise in international trade fetched about by globalisation, the expansion of
information technology, efforts to reduce tax avoidance, and the necessity to
make the law clearer in light of recent court rulings. The Income Tax Act's central
structure has been overburdened and its language has become complicated as a
result of all these revisions. The Act is particularly challenging for the
average tax payer to understand due to the numerous revisions. The Wealth-tax
Act of 1957 has also undergone changes.
3. Therefore, the government made the
decision to update, combine, and simplify the wording and framework of the
direct tax legislation. In August 2009, a draught of the Direct Taxes Code and
a Discussion Paper were made available for public feedback. The Income-tax Act
of 1961 and the Wealth-tax Act of 1957 were to be replaced by the Direct Taxes
Code, a single Act.
Ø Objective
The core objective of direct tax code
bill is:[7]
·
to
rationalize and accumulate all central government direct tax laws.
·
to
advance the effectiveness and efficiency of the tax system.
·
transporting
the combined direct tax law, which comprises the income tax, the dividend
distribution tax, the fringe benefit tax, and the wealth tax.
·
to
achieve horizontal equity among various taxpayer classes in accordance with
best global practises.
·
Tax
regulations must be clear, reliable, and strong if they are to rise acquiescence
even further.
·
to
progressively reduce the amount of tax breaks and deductions in order to increase
and delve deeper into the tax base.
Formerly going over the several
concerns carried up by the Committee and their detailed
observations/recommendations clause-by-clause (Part-II), it may be supportive
to briefly discover the Committee's analysis of certain larger issues:
1. To streamline tax law and broaden the
revenue base, a draught of the Direct Taxes Code, 2009 was released for public
comment. Some of the provisions of that
Draught Code are changed by the Bill.[9]
2. Tax breaks for individuals have been reserved,
but most business exemptions have been eliminated. Individual tax rates have been reduced. Corporate
taxes will subsidize additional to the government's revenue than they did in
the past.
3. In two ways, the Bill might make
compliance more difficult. The General Anti Avoidance Rules' application
circumstances are not specified in any guidelines. The Bill also orders that the tax liability
for income from numerous business units must be resolute separately.
4. The Dividend Distribution Tax and the
Security Transaction Tax are still involved in the Bill. These taxes disturb the idea of progressive
taxation of people since they are levied at a fixed rate irrespective of the
amount of income or profit.
5. The Bill objects to tax foreign
businesses whose "effective management" location at any given time of
the year is in India. What would institute
effective administration of a foreign corporation in India is uncertain.
Ø The Committee's study of the subsequent
broad issues may be fleetingly discussed:
1.
How significantly the 1961 Income Tax Act has been abridged?-
The Committee was concerned in
learning how much the DTC Bill will abridge the current Income Tax Act of 1961.
The Ministry responded in writing as follows: "The Statement of Objects
and Reasons as given by the Finance Minister on August 27, 2010 elucidates that
the 1961 Income Tax Act was revised at least thirty-four times, leading to "complexity in tax
laws" and the incapability of the average tax payer to comprehend it.
Thus, the goalmouth of the new tax code is to amend, syndicate, and simplify
the language and framework of Direct Tax Laws.
When asked what fundamental developments
the Direct Taxes Code has made to the previous Direct Tax Laws to make them
clearer and easier to comprehend, the Ministry responded in writing as follows.
a) By using direct, active speech,
communicating just one idea through a single sub-section, and rearrange the
laws into a logical framework, it streamlines the language of the legislation.
b) 9 provisions (sections 115A to
115BBB) of the Income Tax Act of 1961 currently discourse the tax rates for
non-residents on particular incomes. These are now characterized as special
source incomes, and Part III of the First Schedule of the DTC details the tax
rate.
c) It enhances the taxes rules for
cross-border transactions. It has become vital to establish a robust framework
for the taxation of cross-border trade and global capital in the context of a
globalized economy. These are reflected in the new regulations.
2.
Concerning resident corporations- the challenge raised
is that business income must be calculated distinctly for each distinct and
separate business, irrespective of whether each such business receives tax
benefits, and that given how distinct and separate businesses are well-defined,
a important amount of additional time, effort, and expense is likely to be
incurred.
3.
Taxation of non-residents - It should be noted that taxation of non-residents is a complex
topic as a outcome of globalization, the uncomplicatedness of capital transfers
between nations, the simplicity of changing residence by establishing a company
in a foreign jurisdiction, the rise in transactions between related entities
within multinational corporations, etc. Sovereign governments must discourse
these complications not only in the area of taxation but also in the zones of
business regulation, competition regulation, capital market regulation, and
banking and monetary regulation.
Other nations are also dealing with
these multifaceted issues, and India's provisions concerning the location of
effective management, the indirect transfer of Indian assets outside of India,
and CFC regulations are constant with those in place in other countries.
Protecting one's tax base is crucial in a system with moderate tax rates.
Indian efforts to shield its tax base and make sure that taxes owed to it are
recorded and paid in India would be delayed by the absence of such procedures
and rules.
II.
LITERATURE REVIEW
1.
A picture of the research paper- This paper evolves around the Direct Tax Code (DTC) Bill,
2010, which was an important legislative initiative. The Direct Tax Code, a
single, wide-ranging piece of legislation, was intended to substitute and
modernise the current tax laws, mainly the Income Tax Act of 1961 and the Wealth-tax
Act of 1957.
The Standing Committee on Finance has
given the Chairman permission to present this 49th Report on "the Direct
Taxes Code Bill, 2010.” On September 9, 2010, the Speaker of the Lok Sabha,
acting in accordance with Rule 331E of the Rules of Procedure and Conduct of
Business in the Lok Sabha, referred the Direct Taxes Code Bill, 2010, which had
been tabled in the Lok Sabha on August 30th, to the Committee for review and a
report thereon.
Under this paper the reader will get
the idea of key issues related to tax laws and the observations related to the
same.
Reader would be able to analyse the tax bill by
reading recommendations related to the introduction of the bill.
2.
A summary of the research paper’s main points-
|
Legal Framework- further down this paper the author has conferred
the Bill which comprises the following significant global best practices:
1. Place of effective management will
serve as the company's base of operations.
2. Advance Price Contracts
3. low-tax or uncooperative
jurisdictions
4. Instead of a higher rate of
taxation, international corporations will now be subject to the Branch Profit
Tax.
|
|
Key issues-
1. simplification of Income Tax act
1961
2. Regarding resident
corporations-
3. Taxation of non-residents
|
|
Judicial Rulings- The case mentioned
in the paper highlights the importance of
maintain the separation of power and an independent judiciary when
forming specialised tribunals
|
3.
Gaps in research- the research paper evolves around the important laws that were being
amended by the bill. The research paper does not suggest any suggestion by
authors and is clearly an overview of the bill.
4.
An evaluation of Research paper’s contribution to the topic- This paper will boost the knowledge
of the readers as it explains the concept in an easy and comprehensive
knowledge. All the references mentioned are authentic in nature and can be
beneficial for the reader.
III.
RESEARCH METHODOLOGY-
Qualitative Research- this research is made based on the
observations made by the Standing Committee in
MINUTES OF THE TWELFTH SITTING OF THE STANDING COMMITTEE ON FINANCE
(2011-12) and through 49th Report of Ministry of Finance. This
research is accurate because it is taken from primary sources. All the comments
and observations made by the committee are taken as it is without any
alterations.
The
research is conducted from the official act as well as from books. The said
sources were use and analysed and interpreted based on the facts.
The relevant laws mentioned in the
paper are directly taken from the DIRECT TAXES CODE, 2010 (Bill No. 110 of
2010) and Ministry of Finance, Government of India, Report of the Taxation
Enquiry Commission[10].
All the information was processed
from ministry of finance’s website. The information was analysed and then
distributed as per the headings.
The reason for relying on the primary
sources was its reliability and authenticity.
IV.
LEGAL FRAMEWORK
Ø Key International tax
practices/provisions incorporated in the Code[11]
1. Residence of company to be based on
Place of effective management
Bestowing to the current tax code, a corporation is deemed to
be a resident of India if it was incorporated there or if all of its management
and control are situated there. However, if a corporation's "place of
effective management" is in India, the code treats that firm as if it were
incorporated in India.[12]
2. Provision for Controlled Foreign
Companies (CFC) to offset adjournment of income repatriation[13]
It is also proposed to introduce Controlled Foreign Company
provisions as an anti-avoidance measure, in accordance with generally accepted
practises, so that passive income earned by a foreign company that is
controlled directly or indirectly by a resident of India, and where such income
is not distributed to shareholders resulting in tax deferral, shall be deemed
to have been distributed. As a result, resident shareholders would be required
to pay taxes in India on the dividend they received from the overseas firm.
3. Advance Pricing Agreements[14]
The DTC contains a clause that permits the Board to sign an
Advance Pricing Agreement (APA) with any individual who will be handling an
international transaction. The APA will outline how to calculate the arm's
length pricing in connection to such an international transaction.
Ø New Principles Introduced in DTC
1. Tax rate under the code
All tax rates under the
Code are proposed to be listed in the First through Fourth Schedule of the
actual Code. If there are no plans to alter the tax rates, there is no longer a
need for an annual finance bill. If there are any modifications to the rates,
they will be implemented by suitable amendments to the Schedule that will be
presented to Parliament as an Amendment Bill. Through amendment bills, other
changes to the Code will also be made.
2. Financial year
The income generated in
one year is taxed in the following year under the existing Income Tax Act of
1961. When income is earned, the year is referred to as the "previous
year," and when it is taxed the next year, it is referred to as the
"assessment year." Both compliance and administration have
experienced misunderstanding as a result of the employment of the two
expressions. The previous idea of an assessment year has been abandoned.
According to the Code,
the 'financial year' will be the basis for all of the taxpayer's and the tax administration's
rights and obligations.
3. Total income
To govern the taxpayer's
"total income," the "total income from ordinary sources"
and the "total income from special sources" will be joint.
4. Loses
The loss under the
heading "Capital gains" must be kept isolated, and it cannot be
offset in contradiction of income under other headings. Similarly, any losses
incurred through trading in speculative securities and from maintaining and
caring for horses for the purpose of horse racing will similarly be ring-fenced.
As an alternative of the
current law's limitation of carry forward for only eight years, losses would be
allowable to be carried forward indefinitely for set off against earnings in
the subsequent fiscal years.
5. GAAR- ( General Anti Avoidance Rule)
Tax evasion and avoidance
both considerably impair the fulfilment of the public finance goal of
equitable, efficient, and effective revenue collection. Sectors that offer more
opportunities for tax evasion typically led to distortions in the way resources
are allocated.
The DTC has implemented a
general anti-avoidance regulation that will function as a deterrent against
such behaviours.
6. Arrangement of Income
In principle, all
accruals and receipts in the arrangement of revenue must be categorised as either
"special sources" or "ordinary sources."
Nothing can be deducted,
and the gross amount is liable to tax, usually at a reduced rate. This is how
presumptive taxation is used. Only the percentage of these "special
source" incomes that is derived from India is subject to tax under the
Code, hence they are primarily applicable to non-residents. The "ordinary
sources" of income are determined by determining the net income after
deducting permissible expenses from revenues and are applicable to both
residents and non-residents conducting business through a permanent presence in
India.
An "ordinary
source's accruals or revenues will be further categorised under one of the
following five heads:
Income from:
A. Employment
B. House property
C. Business
D. Residuary Source
E. Capital Gains
V.
JUDICIAL RULINGS
1.
The McDowell's Case rule[15] (henceforth referred to as
"McDowell") has generated a great deal of debate in the field of tax
governance. On the one hand, it might appear to have fundamentally altered tax
planning and fiscal jurisprudence in India, but some authors believe that this
is untrue and that the Supreme Court's otherwise persuasive explanation of
fiscal principles is only an aberration.[16]
The ambiguity surrounding the legal position on tax planning has been
exacerbated by judicial pronouncements made subsequent to the McDowell case.
This has led to radically different opinions about what should and should not
be allowed when determining an assessee's tax liability through transactions.
Consequently, it is argued that removing much of the surrounding gloss is
essential to determining the precise impact of the judicial pronouncements in
question. This will allow us to answer two questions: what the court actually
did and what it intended to achieve.
2.
In Vodafone[17], the Bombay High Court determined
the nature of the transaction for the narrow goal of deciding that the notice
was not completely nonest26. It did this on two reasons by upholding the
show-cause notice given to the petitioners. First off, the deal involved the
transfer of the subsidiary's underlying assets rather than just shares, which
would have transferred the Cayman Islands entity's majority interest in its
Indian subsidiary. Any profit made by the subsidiary would be subject to
taxation in India as "capital gains" since it would be seen as the
transferee's profit as well as the profit of the "shell company."
Second, the Court determined that a simple transfer of the controlling interest
implied a transfer of several valuable intangible assets, including the right
to conduct business and run mobile phone operations in India, which transfer
was taxable in India, even in the absence of "piercing the veil" and
treating the subsidiary's assets as the subject of the transfer.
VI.
KEY FINDINGS AND RECOMMENDATIONS
With regard to further direct tax
reforms, it may be mentioned that tax experts have proposed a Direct Tax Code
(DTC) to simplify the structure of India's direct tax laws into a single Act
and replace the existing Income Tax Act, 1961. and other direct tax laws
related to wealth tax and dividend tax. Direct tax laws are proposed in three
strategies to expand the tax base.[18]
(1) Minimize tax breaks and tax
breaks that erode the tax base.
(2 ) removing loopholes and anomalies
in existing direct tax laws that facilitate tax avoidance; And
(3) Combating tax evasion.
1. Case Management: Amendments to
Sections 147 and 148 of the I-T Act allow tax authorities to reopen assessment
cases based on pre-defined criteria.[19]
·
I-T
personnel can examine the assesses books and records going back six years.
·
These
regulations are currently open to interpretation. 40% of the cases are because
the assessed challenges the reasons given by the officer for reopening the
case.
·
Increased
threshold limit for filing a claim: Now it is more than Rs 100,000. The
predetermined criteria for selecting cases for review will also be tightened.
·
Proper
reasons must be supported to reopen the case.
·
Assessment
procedures should be faceless and citizens should have the option to explain
tax issues to CBDT.
2. Reducing the burden of tax
compliance[20]:
tax compliance based on global trends and best practices. This is expected to
increase transparency among taxpayers and broaden the tax base.
·
Use
of artificial intelligence (AI) in tax compliance and administrative processes.
·
Cooperative
compliance proposal in direct taxes department. It integrates data from banks,
financial institutions and the Goods and Services Tax (GST) network to ensure a
wide range of taxable income.
3. Personal income tax: Tax rates
are set between 5 and 20 percent.[21]
Currently, the personal income tax
structure is divided into three categories based on age. People under 60 years
old, people over 60 years old but under 80 years old, and the third category are
people over 80 years old.
·
There
are four berths in the first category where income up to Rs 2.5 lakh is exempt
from tax. A tax rate of 5% applies to incomes between Rs 2.5 million and Rs 5
million, a tax rate of 20% applies to incomes between Rs 5 million and Rs 1
million and a tax rate of 30% applies to incomes above Rs 1 million. The second
tier has a base slab of Rs 300,000 and the third tier has a 'zero' interest
rate for income up to Rs 500,000.
4. Corporate tax will be 25%[22]
·
The
government plans to reduce the corporate tax rate to 25% in a phased manner for
all companies, including large companies with an annual turnover of more than
Rs 400 crore.
·
Over
the past five years, the government has gradually reduced the tax rate from 30%
to 25% for 99.3% of businesses.
·
However,
the 0.7% of large companies that do not take advantage of this benefit account
for almost 80% of the total corporate tax collection and are subject to up to
30%.
·
The
proposed reduction in corporate income tax will apply to both large local and
foreign companies operating in India without a subsidiary and taxed at 40%.
The direct tax law is expected to
lead to benefits such as increased tax-to-GDP ratio, increased GDP growth,
improved fairness, lower administrative burden and lower compliance costs. In
connection with the implementation of the Act on Direct Taxes, it can be
pointed out that the proposed tax reform has yet to be implemented. Although
the Direct Tax Bill was introduced in Parliament in 2010 and a revised version
of the bill was issued by the government in 2014, the bill could not be passed
in Parliament due to the fall of the then government. In 2017, the government
established an expert commission to draft a new code of direct taxes. Although
the committee's report was submitted to the Finance Minister, Ms. Nirmala
Sitaraman on 19 August 2019, the report has not yet been made public.[23]
VII.
CONCLUSION
The Direct Tax Code (DTC)
Bill of 2010 represented a significant step towards modernizing India's direct
tax system. The objective of the proposed Direct Taxes Code (2010) is to create
a single piece of legislation known as the Direct Taxes Code (DTC), which would
substitute both the Income Tax Act of 1961 and the Wealth Tax Act of 1957. The
Direct Taxes Code was introduced with the claimed goals of streamlining the tax
system, reducing litigation, expanding the revenue base, and doing away with
exemptions. Despite having objectives to reduce tax evasion and simplify
India's direct tax system. The law has enormous potential to streamline
taxation, lower tax evasion, and comply with global best practises. However, it
encountered difficulties, complexity, and amendments throughout the legislative
process. There have been numerous adjustments and discussions as a result of stakeholder
concerns, the complexity of the additional laws, and shifting political objectives.
The DTC bill of 2010 ran across a number of obstacles that hindered its
advancement. These difficulties can be explained as follows:
Ø Stakeholder Concerns: Businesses, tax professionals, and
the general public were among the stakeholders who engaged in extensive
discussion and debate over the proposed legislation. The projected elimination
of tax deductions and exemptions was one of the main points of dispute. Many
people claimed that these exclusions were necessary for promoting investment
and economic expansion.
Ø Complexity of the Tax System: The bill offered new ideas and
regulations while also attempting to simplify the tax system. Some of these new
rules, such as the adoption of General Anti-Avoidance Rules (GAAR), have drawn
criticism since they are thought to complicate the tax code and increase the
likelihood of disagreements between taxpayers and tax authorities.
Ø Economic Effects Concerns about the DTC bill's possible effect
on economic growth have been voiced by some experts and industry executives.
They were concerned that eliminating such tax breaks may deter investment and
weaken India's competitiveness.
Ø Political changes include: During the course of the bill's
passage through the parliamentary process, India's government underwent changes
and its political priorities shifted. As a result, the government's strategy
for tax reform changed, which hampered the bill's advancement.
The DTC bill sought to harmonise
India's tax system with global best practises by modernising and streamlining
it. However, because there are so many competing interests, reaching agreement
on such measures frequently takes time.
[1] Lok Sabha, F. (2012). STANDING COMMITTEE ON FINANCE
(2011-12) THE DIRECT TAXES CODE BILL, 2010 FORTY-NINTH REPORT LOK SABHA
SECRETARIAT NEW DELHI (Saka) 2 FORTY-NINTH REPORT STANDING COMMITTEE ON FINANCE
(2011-2012) (FIFTEENTH LOK SABHA) THE DIRECT TAXES CODE BILL.
[2] Supra note 1
[3] Supra Note 1
[4] Standing Committee, Supra note 1
[5] Supra Note 1
[6] Dr. Justice A.R. Lakshmanan, D.D.
Basu, Shorter Constitution of India, 1683 (14th Ed. 2009).
[7] Dr. Justice A.R. Lakshmanan, D.D.
Basu, Shorter Constitution of India, 1683 (14th Ed. 2009).
[8] Lok Sabha,
F. (2012). STANDING COMMITTEE ON FINANCE (2011-12) THE DIRECT TAXES CODE BILL,
2010 FORTY-NINTH REPORT LOK SABHA SECRETARIAT NEW DELHI (Saka) 2 FORTY-NINTH
REPORT STANDING COMMITTEE ON FINANCE (2011-2012) (FIFTEENTH LOK SABHA) THE
DIRECT TAXES CODE BILL.
[9] Supra note 7.
[10] Vol. III, (New Delhi, India, 1953-54), 181-330.
[11] THE DIRECT TAXES CODE, 2010. (n.d.).
[12] Ibid.
[13] Ibid.
[14] Ibid.
[15] McDowell and Co. Ltd. v. CTO,
(1985) 3 SCC 230 : AIR 1986 SC 649.
[16] See Nani Palkhivala et al., The Law and Practice of Income Tax
66 (9th Edn., Dinesh Vyas Ed., 2004)(hereinafter “Palkhivala”).
[17] Vodafone International Holdings v.
Union of India, 2008 SCC OnLine Bom 1152 : (2009) 311 ITR 46.
[18] Rao, K. R. and Chakraborty, P.
2010. Goods and services tax in India : An Assessment
of the Base, Economic & Political Weekly, XLV (1),
January 2.
[19] Rao, M., Rao, G. and Rao, K. R.
2009. Direct taxes code : Need for greater reflection,
Economic & Political Weekly, XLIV( 37), September
[20] Shetty, S.L. 2010. Mare tax
concessions for more inequality, Economic & Political
Weekly, 2010 XLV (11).,March 1
[21] Shetty, S.L. 2010. Mare tax
concessions for more inequality, Economic & Political
Weekly, 2010 XLV (11).,March 1
[22] Rao, M., Rao, G. and Rao, K. R.
2009. Direct taxes code : Need for greater reflection,
Economic & Political Weekly, XLIV( 37), September.
[23] The Indian Journal of Commerce
Vol. 64, No. 2, April-June 2011.
Article Information
AN OVERVIEW OF DIRECT TAXES CODE BILL
Authors: AYUSH PATIDAR, SNEHA SHARMA
- Journal IJLRA
- ISSN 2582-6433
- Published 2024/05/22
- Issue 7
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International Journal for Legal Research and Analysis
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