CBDT Amends Safe Harbour Rules for Intra-Group Loans


On 19 December 2023, CBDT has further extended the Safe Harbour Rules (SHR) for international transactions, i.e. rules 10TA and 10TD of Rules, vide a Notification No.104/2023/F. No. 370142/26/2023-TPL. These amendments will come into force from 1 April 2024 (i.e. AY 2024-25 and onwards).  The amendments broadly provide change in the definition of operating expenses, intra-group loan transaction, benchmark interest rate in view of alternative reference rate after discontinuation of LIBOR.

In the attached Newsflash, the aforementioned amendments in SHR are highlighted for ready reference. Hope you find the same useful.

Please let us know if you have any questions or require any clarification in this regard