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ARTICLE · 20 APRIL 2026

Navigating India’s New Income Tax Code: A Comprehensive Compliance Guide For MNCs & Japanese Subsidiaries

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India’s income tax architecture has undergone its most sweeping structural overhaul in over six decades. The Income-Tax Act, 2025 (IT Act, 2025)...

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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

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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