Section 52 : Principles of taxation applicable in respect of entities

1) For purposes of payment of tax, any entity shall be responsible distinctly from its beneficiaries.

2) Distributions to be made by an entity shall be as mentioned in Section 53, and in distribution to be so made, tax shall be imposed on its beneficiaries pursuant to Section 54.

3) The amounts derived by and expenses borne by an entity shall be deemed to have been received or borne by the entity irrespective of whether or not the entity has derived the same or borne expenses for another person.

4) A property under the ownership of an entity and the liability borne by it shall be deemed to be under the ownership or burden of the entity. Such property under ownership and liability borne shall not be deemed to be under the ownership or burden of any other person.

5) Foreign income tax paid by the manager, the beneficiary of an entity or the entity, whosoever, for the income of the entity shall be deemed to have been paid by the entity.

6) Transactions between any entity and its managers and beneficiaries shall be recognised subject to Chapter 7 and Section 45