CMA Final · December 2025 · Paper 15
CMA Final Direct Tax Laws and International Taxation December 2025: paper analysis
Our own analysis of the official paper, as of 12 October 2026. The questions and answers belong to ICMAI; read them on ICMAI's website.
Chapter-wise marks
Where the marks were in this paper (out of 100; internal-choice alternatives not double counted).
What each question tested
In our words, by question number. Open the official paper for the full question.
| Q | Marks | Tests | Chapter |
|---|---|---|---|
| 2(a) | 7 | Total income of a charitable trust running a hospital and college, with deemed application and accumulation options | Assessment of Trusts |
| 2(b) | 7 | Tax on a firm and a retiring partner when stock and land are distributed in settlement of capital | Business Restructuring |
| 3(a) | 7 | Comparing an individual's tax under the default and old regimes with capital gains, insurance premium and donation | Assessment of Individuals including Non-residents |
| 3(b) | 7 | Company tax under normal provisions versus the concessional new-manufacturing regime with losses and deductions | Assessment of Companies |
| 4(a) | 7 | Capital gains for a shareholder on demerger: apportioning cost between original and resulting company shares | Business Restructuring |
| 4(b) | 7 | Total income and tax of a non-resident Indian under the special provisions for investment income | Assessment of Individuals including Non-residents |
| 5(a) | 7 | Time limits for filing and disposing of a first appeal, condonation of delay and tax payment before appeal | Assessment Procedure including Dispute Resolution Process |
| 5(b) | 7 | Actual cost of machinery acquired for shares and imported on credit under ICDS, with tax depreciation | Income Computation and Disclosure Standards (ICDS) |
| 6(a) | 7 | Exemption, credit and tax sparing methods of double taxation relief | Double Taxation Avoidance Agreements (DTAA) |
| 6(b) | 7 | Total income and unilateral relief for a resident with foreign business, royalty and capital gains | Double Taxation Avoidance Agreements (DTAA) |
| 7(a) | 7 | Arm's length price using comparable uncontrolled price with a warranty adjustment and its effect on income | Transfer Pricing |
| 7(b) | 7 | Interest limitation rule for borrowings from or guaranteed by associated enterprises | Transfer Pricing |
| 8(a) | 7 | Book profit for minimum alternate tax with additions, deductions and brought-forward losses | Assessment of Companies |
| 8(b) | 7 | Classifying transactions as international, specified domestic or regular business transactions | Transfer Pricing |
What stood out
- International taxation again carried a heavy share: four transfer pricing parts or MCQ clusters plus a DTAA theory and relief computation.
- Assessment of individuals, companies and trusts formed the computational core, with regime comparisons appearing for both an individual and a company.
- Business restructuring was tested twice (retiring partner distribution and demerger capital gains), more than in June 2026.
- Only one written part was pure theory (methods of double taxation relief), so practice in computation is essential for this paper.
- MCQs spread across administrative areas such as interest, penalties, survey powers, Black Money Act valuation and GAAR timelines.
Practise the chapters that carried the marks
Transfer Pricing, Double Taxation Avoidance Agreements (DTAA), Assessment of Individuals including Non-residents: study guides and practice questions in the CMA Final format.