Overview

• Apple is lobbying to amend the 1961 Income Tax Act so owning high‑value assembly machines in contractors’ plants does not create a taxable “business connection.”
• A senior Indian official says the request is under review, as authorities balance investment goals with preserving the right to tax foreign companies.
• Tax advisers warn Apple could face billions in exposure if equipment ownership is treated as a basis to attribute iPhone profits to India for taxation.
• Apple’s India manufacturing push has accelerated, with the country accounting for roughly 25% of global iPhone shipments and Foxconn and Tata investing over $5 billion to open five plants.
• Experts cite a 2017 Supreme Court ruling on Formula One’s control of a venue as a relevant precedent, while industry groups note contract manufacturers cannot finance all specialized machinery without Apple’s ownership.