Executive Summary
India’s income tax architecture has undergone its most sweeping structural overhaul in over six decades. The Income-Tax Act, 2025 (IT Act, 2025) replaces the Income-Tax Act, 1961 (IT Act, 1961), effective 1 April 2026, and is accompanied by the Income-Tax Rules, 2026 (IT Rules 2026), notified by the Central Board of Direct Taxes (CBDT) on 20 March 2026.
This article provides a comprehensive, practitioner-oriented guide to every material change relevant to MNCs and their Indian subsidiaries, with particular emphasis on cross-border payment mechanics, Transfer Pricing (TP) compliance, DTAA relief procedures, and the new TDS framework.
Overall Compliance Framework – Key Structural Changes