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Case lawAdvance Ruling › In re Vanenburg Group B.V.
Advance RulingHelps taxpayerValidity unconfirmeds.45s.195s.139s.92s.9(1)(i)s.90(2)DTAA art 13

In re Vanenburg Group B.V.

Our Dutch company is moving its Indian subsidiary's shares to another group company in the Netherlands. If the gain is exempt under the treaty, do we still have to withhold, file a return and do a transfer pricing study?

Our Dutch company is moving its Indian subsidiary's shares to another group company in the Netherlands. If the gain is exempt under the treaty, do we still have to withhold, file a return and do a transfer pricing study?

No, on all four counts. The Authority ruled that no taxable capital gain arose in India on Vanenburg Group B.V.'s proposed transfer of its shares in Cordys R&D (India) Pvt Ltd to Cordys Holding B.V., because article 13(5) of the India-Netherlands agreement leaves such gains taxable in the Netherlands where the transfer is part of a corporate reorganisation and the alienator holds at least ten per cent of the transferee. It followed that the transferee need not withhold under section 195, that no return was required under section 139, and that the transfer pricing provisions in sections 92 to 92F did not apply. The ruling binds only Vanenburg.

Pronounced by the Authority for Advance Rulings (Syed Shah Mohammed Quadri, J. (Chairman) and A. Sinha, Member) on 2007-01-31, reported as [2007] 289 ITR 438 (AAR). It bears on section 45, section 195, section 139, section 92, section 9(1)(i), section 90(2), section DTAA art 13 of the Income Tax Act 1961, in Capital Gains and TDS Defaults matters.

Validity check could not be completed. No decision dealing with this ruling was found on Indian Kanoon. The section 195 limb is supported by the Supreme Court in GE India Technology Centre P. Ltd v. CIT (9 September 2010), which held the withholding obligation arises only where the sum is chargeable under the Act - that much can be relied on. The other limbs were not established. The Finance Act 2012 made extensive retrospective changes to section 9(1)(i), including Explanation 5 on shares deriving their value substantially from Indian assets, and the general anti-avoidance rules and the principal purpose test under the Multilateral Instrument now stand in front of any treaty exemption claimed on an intra-group reorganisation. Whether the India-Netherlands agreement is a covered tax agreement under the MLI was not verified. The Authority itself was replaced by the Board for Advance Rulings from 1 September 2021 (Finance Act 2021; Notification 96/2021), whose rulings are appealable to the High Court under section 245W, and the Income-tax Act 1961 was replaced by the Income-tax Act 2025 from 1 April 2026.

Why it matters

This is the ruling cited for the proposition that the machinery follows the charge. Once the treaty allocates the gain away from India, the Authority held there was no occasion to call a machinery section in aid: section 195 bites only where the income is taxable under the Act, the return obligation falls away, and the transfer pricing provisions, which exist to compute income, have nothing to compute. The Supreme Court took the same view of section 195 in GE India Technology Centre P. Ltd v. CIT, decided 9 September 2010, holding that the obligation attaches only to sums chargeable under the Act. Whether the return and transfer pricing conclusions have survived later amendment is much less certain, and a reader should check the current position before acting on those limbs.

Binding only on the applicant who sought it, in respect of the transaction the ruling was sought on, and on the Principal Commissioner or Commissioner and the authorities subordinate to him in respect of that applicant and that transaction — and only until the law or the facts change (section 245S). It binds nobody else. The Tribunal and the courts nonetheless treat a considered ruling as persuasive, which is why practitioners cite them.

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