Overview

• Apple has asked New Delhi to modify the 1961 Income Tax Act so that owning high‑value iPhone assembly machinery at contractors’ plants does not create a taxable business connection.
• Tax experts warn the current interpretation could expose Apple to billions of dollars, with the 2017 Supreme Court ruling in the Formula One case cited as a relevant precedent on control and taxation.
• A senior government official says discussions are underway and calls the decision a tough call given concerns about preserving India’s right to tax foreign companies.
• India’s role in Apple’s supply chain has expanded rapidly, with the country now accounting for roughly 25% of global iPhone shipments and contractors Foxconn and Tata investing over $5 billion across five plants.
• Apple’s equipment‑ownership model draws on its China practice where no comparable tax applies, and industry group ICEA has urged legal clarity, noting contract manufacturers cannot finance such costly machinery.