14 september 2017 · winner of india tax firm of the year 2016 at the asia tax awards. • the new...

Winner of India Tax Firm of the Year 2016 at the Asia Tax Awards

Recent Trends in M&A Landscape In India

14 September 2017

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Need for Restructuring

Recent M&A Transactions

Generally Adopted Options for Restructuring

Key Initiatives

Provisions of Tax on Indirect Transfers of Indian assets

Case Study on Indirect Transfer Provision

Implications of earn-out arrangements

Tax Implications on Non – Compete payments

Possibility to claim tax depreciation on Goodwill arising on account of restructuring

Carryover of tax losses

Changing Paradigm General Anti-Avoidance Rules and BEPS

Other Key Considerations in Structuring

Contents

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Need for Restructuring

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NEED OF RESTRUCTURING

414-09-2017

Consolidation of Businesses, Forward & Backward integration

Achieve Synergies & Growth in Business, Eliminate Competition

Improving Financial Performance

Dealing with New Regulation / Developments

Hiving off of business – Focus on particular business

Promoters Wealth Planning – Succession Planning, Family Settlements / arrangements, etc

Unlocking shareholders value

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Recent M&A Transaction

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Recent M&A Transactions

614-09-2017

Jio Triggered Consolidations in Telecom Sector

Objectives of the merger• Sustain high level competition• Improve cash flows• Maintain the market position• Reduced pricing• Increase in revenue• Better customer services

Tata Sons to acquire Group entities shares

Consolidation of State Bank with its associate banks

Objectives of acquisition• To unwind cross holding

structure in group companies (being Tata Chemicals and Tata Global Beverages)

• Increases its holding in operating companies

• Protects its interest by safeguarding from hostile takeovers

• Allow Group companies to encash their holding and utilise proceeds to reduce their debt / finance growth other plans

Objectives of the merger• Decrease in unhealthy

competition among PSBs• Better profitability • Better focus on defaulters • Less investment on technology &

compliance• More services under one roof

By this consolidation, SBI will probably join the league of top 50 banks globally

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Generally Adopted Options for Restructuring

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GENERALLY ADOPTED OPTIONS FOR RESTRUCTURING

14-09-2017 8

Business

Restructuring

Share PurchaseBusiness

PurchaseDemergerMerger

Internal

RestructuringAcquisitionMerger/Demerger

Slump Sale Itemized Sale

Business

Succession

Capital

Reduction/Buy-back

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Key Initiatives

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• The New Companies Act, 2013 provides liberalised / fast track procedures for the following:

− Merger of small companies

− Merger of holding and wholly-owned subsidiary company

• Also, the New Companies Act allows cross-border mergers where transferor is an Indian company and transferee is a Foreign Company

• Establishment of National Company Law Tribunal – to assume jurisdiction of High Court for sanctioning M&A Schemes

• RBI permit deferment of consideration in share purchase / sale transaction to the extent of 25% - maximum period 18 months

• The New Act requires intimation of scheme to various authorities including RBI, SEBI, Income Tax, Competition Commission etc. – Thus providing opportunity to all regulators to make their representations.

• Commitment - No Retrospective Amendments

• Integrating tax laws with global practices

− Adopting BEPS Action Plan and Signing of MLI

− Changes in domestic laws in line with BEPS – Patent Box Regime, County by Country Reporting, Equalisation Levy, etc.

Key Initiatives

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Provisions of Tax on Indirect Transfers of Indian assets

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PROVISIONS OF INDIRECT TRANSFER - OVERVIEW

Indian Companies

Offshore entity

Popular Jurisdiction

India

Outside India

Background of indirect transfer provisions

• Provisions introduced in 2012 after Government lost the tax case against Vodafone in the Supreme Court

• Although introduced in 2012, applicable retrospectively from 1 April 1962

• As per amended law, gains of non-resident from transfer of share / interest in an overseas company / entity taxable in India if such share / interest derives its value substantially from assets located in India

• In this example, gains of Investors from sale of shares of Offshore entity can be taxable in India

Investors

Derives Value substantially from

assets located in India

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Main Provision

• Gains of non-resident from transfer of share / interest in an overseas company / entity taxable in India, if such share / interest derives its value substantially from assets located in India (as per Explanation 5 to section 9(1)(i) of the Act)

Substantial value

• The value of the overseas company / entity deemed to derive its value substantially from Indian assets if on the specified date1:

• Value of assets in India exceeds INR 100 million (approx. USD 1.47 million); and

• Value of Indian assets is 50% or more of value of all assets owned by overseas entity(as per Explanation 6 to section 9(1)(i) of the Act)

Exemption from

provisions

• Exemption provided only to small shareholders, which:• Do not hold any right of management or control in such overseas entity and

• Do not hold more than 5% of voting power/share capital/ interest in overseas entity (at any time in 12 months period preceding the date of transfer) directly owning the assets in India(as per Explanation 7 to section 9(1)(i) of the Act)

13

PROVISIONS OF INDIRECT TRANSFER - OVERVIEW

1. Specified date –• Date on which the accounting period of the company/entity ends preceding the date of transfer of share/interest.• Date of transfer, if the book value of assets of the overseas entity on the date of transfer exceeds book value of assets as on last day of preceding accounting year, by fifteen

percent.

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Non-resident transferor:

- Required to obtain PAN

- Pay tax on gains in India

- File tax returns in India

- CA certificate / report in Form 3CT

Buyer:

- Required to obtain TAN

- Withhold tax at time of payment of consideration

- File withholding tax returns

Indian entity whose shares indirectly transferred:

Report transaction to ITA

- Within 90 days of transaction (if management / control right transferred)

- Within 90 days from end of financial year in other cases

Details to be furnished in Form 49D

IMPLICATIONS OF INDIRECT TRANSFER PROVISIONS

IF INDIRECT TRANSFER APPLIES

Failure to comply with indirect transfer provisions could lead to penalty in addition to applicable tax and interest.

IT Demands (in Billion $) - Vodafone ~ 1.7 and Hutchinson ~ 5, Cairn UK - ~1.5

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Case Study on Indirect Transfer Provision

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Winner of India Tax Firm of the Year 2016 at the Asia Tax Awards 1614-09-2017

An insight on the decision in Cairn Energy Case (only relevant entity structure covered)

Cairn UK Holding Limited (CUHL-UK)

Cairn India Holding Limited (CIHL-Jersey)

The 9 Indian Subsidiaries

WOS

Cairn India Limited (CIL - India)

Public shareholders

Incorporation of WOS1 2

3

IPO

The entire restructuring resulted in unlocking the value of investment in India through listing of CILand aligning all the investments deriving their value substantially from assets based in India

Applicability of Indirect Transfer

Provisions??(Tax ~ Bn 1.5 $

Interest ~ Bn 2.7 $)

Entire holding of CIHL transferred by CUHL to CIL in 2007 as a part of internal restructuring of group

undertaken for improving operational efficiencies

WOS

Pre Transaction structure

69%

31%

Indirect Transfer – Benefit under DTAA –Sanofi case

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Implications in case of earn-out arrangements

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Background• Payment of consideration in share acquisition

transactions are often structured in two parts -Upfront and Deferred consideration (parked in an escrow account)

• Parameters for deferred consideration could be based on:− Achievement of certain EBITDA targets

− Outcome of key / long drawn litigations

− Other contingent event or mutually agreed terms between parties

• Transfer of shares attracts Capital Gains taxability

• Further, where seller is a Non Resident, the buyer is obliged to withhold tax

Issues• Nature of income (whether Capital Gains?)

• Point of Taxation - The most debated issue – whether taxable in the Year of:− Execution of SPA or

− Receipt of consideration

Earn-out arrangements

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Point of Taxation:

• The said aspect has been a matter of tremendous litigation in India. Position of immediate taxability leads to:− Disproportionate tax outflow for the seller and

− No mechanism of recovery of tax paid in event of reduced consideration (if time line for revising the return has lapsed)

• While some courts have applied the principle of accrual (right to receive the amount) others have followed strict interpretation of law that capital gains are taxable in the year of Transfer itself.

• The overall judicial position suggests that the taxability is dependant on the factual matrix of each case.

• Some of the key aspects / factors considered by courts while allowing deferral:

− The earn-out payment is contingent upon outcome of future event

− It is not an assured consideration receivable by the seller

− It only provides a cap on the maximum consideration receivable

− Non payment does not lead to dilution in the rights of the buyer with respect to the asset acquired

Taxability of deferred consideration (earn-out)

1914-09-2017

Position continues to be litigative and will be driven by factual matrix of each case

Nature / Characterisation of deferred income

• If it is dependent upon continuance of employment by the Promoter for achieving EBITDA / targets, the same may be classified as Income from Salary

• Else it shall be taxable as Capital Gains

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Tax Implications on Non – Compete payments

2014-09-2017

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Winner of India Tax Firm of the Year 2016 at the Asia Tax Awards 2114-09-2017

Tax implications of non-compete fees

Transferor’s Perspective (Seller)

• Considering that only revenue receipts are taxable, the sellers were characterising the receipt as ‘Capital Receipt’ which led to huge litigationaround its taxability

• The litigation was put to rest with an amendment in the ITA – post which taxable such receipts are now taxable as business profits

• Only exceptions are receipts on transfer of right to carry on business chargeable under the head “Capital gains”

Transferee’s Perspective (buyer)

• Whether Revenue expenditure or Capital expenditure eligible for depreciation

• Courts have commonly held as capital expenditure when arrangement is for a substantial period of time and akin to capital asset

• However, divergent views exist on allowability of depreciation on such capital expenditure

• It is pertinent that the said aspect is duly considered while structuring the M&A documents agreement

In view of divergent legal position, taxability of non compete fees continues to be complex and litigative matter.

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Goodwill arising on Amalgamation – whether entitled to depreciation?

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• ‘Goodwill’ = Excess of consideration / price paid over the value of identified assets acquired

• Goodwill does not find an express mention in the list of intangible assets eligible for depreciation as per ITA

• Accordingly, claim of depreciation on Goodwill was subjected to substantial litigation until the Supreme Court recognized it as an eligible asset and allowed the claim of depreciation on the same arising in the case of SmiffSecurities which dealt with a scenario of amalgamation

• However, SC has not categorically commented on Explanation 7 to section 43(1) of ITA in context of amalgamation:

• “Where, in a scheme of amalgamation, any capital asset is transferred by the amalgamating company to the amalgamated company and the amalgamated company is an Indian company, the actual cost of the transferred capital asset to the amalgamated company shall be taken to be the same as it would have been if the amalgamating company had continued to hold the capital asset for the purposes of its own business”

Goodwill – Arising on restructuring transaction

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• Recently the Bangalore Tribunal has interpreted the Supreme Court’s ruling differently and disallowed the taxpayer’s claim of depreciation on goodwill on the principle that tax advantage cannot be derived out of a tax neutral transaction

• The Tribunal’s ruling suggests the below:

− Depreciation is allowable only where goodwill is supported by material evidencing the benefit derived by the taxpayer

− If it is merely an arithmetic difference between the consideration paid and assets acquired, it is not eligible for depreciation

Goodwill – Arising on restructuring transaction

2414-09-2017

This ruling is likely to reignite litigation around depreciation on goodwill arising from business restructuring transactions

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IND AS Implication on - Goodwill

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• Applicable to –

− All listed entities and those in the process of listing

− Unlisted companies having Net-worth => 250 Crores

− Holding, Subsidiary and JV’s of above entities

• IND -AS – 103 ‘Business Combination’ deals with accounting of transactions resulting in acquisition of control over a business / entity (Demerger/slump sale/share purchase etc.)

Method of Accounting

Common Control Business

CombinationThird Party Acquisition

Pooling of interests method to be followed

i.e. recording of assets and liabilities at

carrying amounts and transferring the

difference to Reserves

No Goodwill will be recorded

Acquisition Method to be followed -

Required recording of assets and

liabilities at fair values

Goodwill = Consideration (-) Value of all identifiable assets

and liabilities. However, the same is not subject to

amortisation in books.

Tax perspective – position remains same

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Carryover of Tax Losses

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Carry forward of losses of closely held company - Section 79

2714-09-2017

Target Company

(I Co.)

AcquirerExisting

Shareholders (NR)

Share Transfer

Consideration

Target Company

AcquirerExisting

Shareholders

Mechanism 1: Purchase of shares of Target Co. from the Existing shareholders

Mechanism 2: Subscribe to fresh issue of shares of Target Company

Carry forward and set off of loss is allowed to a closely held company only if:

Shares carrying 51% of the voting power are beneficially held by same persons in year of :

• Incurrence of loss and

• Year of change of shareholding

Exceptions: if change is due to:

Death of a shareholder

Transfer by way of gift to relative or

Amalgamation / Demerger of Foreign company

Applies only to business loss and not to unabsorbed depreciation

Not applicable to eligible start-ups

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Beneficial ownership - whether w.r.t. immediate or ultimate shareholder ?

2814-09-2017

Promoters

B Pvt Ltd

C Pvt Ltd

100%

98%Merged

Provision of section 79 will not be applicableCIT vs. Select Holidays Resorts (P.) Ltd. [2013] 35 taxmann.com 368 (Delhi HC)

The Tribunal held in favour of assessee holding that: • there was no change in control and management of

amalgamated company pre and post merger. • merger in this case is akin to a death of shareholder.

The High Court upheld the view of the Tribunal.Karnataka HC has also ruled in favour in case of transfer of shares where ultimate beneficiary remained the same.

A Pte Ltd

A1 Pvt Ltd

B Pvt Ltd

A2 Pvt Ltd

100%Merged

100% 100%

Provision of section 79 will be applicable in hands of B Pvt Ltd?Yum Restaurants (India) Pvt. Ltd. vs. ITO (ITA No. 1097/Del/2014)

• For the purpose of Section 79 immediate shareholding has to be seen and not the ultimate beneficial ownership.

• Taxpayer in this case did not cite the earlier ruling of the same High Court

Divergent views are expressed by the judicial authorities in this regards and hence the issue is not free litigation

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Amalgamating Company: Tax Losses and Unabsorbed Depreciation – Section 72A

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Unabsorbed losses (other than speculation business) and depreciation of company A allowed in the hands of company B.

Conditions: Amalgamating Company• Must be engaged in the business for 3 years prior to the date of

amalgamation

• Has held as on the date of amalgamation, at least 3/4th of the book value of fixed assets held by it 2 years prior to the date of amalgamation.

Conditions: Company B• 3/4ths of book value of fixed assets acquired should be continuously

held for 5 years

• Continue the business of amalgamating company for 5 years

• Achieve production of at least 50% of the capacity level of amalgamating company within 4 years

• Maintain the production at minimum 50% level for 5 years from the date of amalgamation

General Conditions

Amalgamating company must be:

• A company owning an industrial undertaking, ship or hotel

• Specified banking company

• Public Sector company engaged in the business of operation of aircraft

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General Anti-Avoidance Rules

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Applicability: FY 2017-18

GAAR - Basic Provisions

3114-09-2017

Main purpose of arrangement is to obtain a tax benefit

AND

Not at arm’s-length

Misuse/Abuse of tax provisions

Lacks Commercial substance

Lack of Bona-fide purposeOR OR OR

Consequences of Impermissible Avoidance Arrangement

Disregard / Re-characterise/

Combine arrangement / accommodating

party and connected persons

Disregard corporate structure

Deny Treaty Benefit

Re-allocate expenses, income,

relief, etc.

Re-characterize equity-debt,

expenses, income, relief, etc.

Re-assign place of residence/ situs of

assets or transaction

Tax Benefit defined to cover reduction / deferral of tax under provisions of the Act or as a result of tax treaty

Consequence - Denial of Tax Benefits

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• Tax benefit in aggregate to all parties does not exceed INR 30 million during the year

• Grandfathering of investments made before 1st April 2017. However, grandfathering would not apply to tax benefit obtained from “arrangement” even when entered into before 1st April 2017

• When the tax implications of the arrangement have been explicitly and adequately considered at the time of sanctioning such arrangement by the Court. (Question no. 8 of Circular No. 7 of 2017)

• Where the tax avoidance is ‘sufficiently addressed’ by LOB clause in the treaty (i.e Treaties which provide for both PPTas well as bonafide purpose test). (Question no. 2 of Circular No. 7 of 2017)

Basic Provisions | Exceptions

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Dark Clouds of GAAR

3314-09-2017

Merger of loss making entity into profit making

entity

Conversion of debt / ECB into equity capital

Conversion of Company into LLP

Use of tax friendly jurisdiction to route

investment into IndiaSelection of one of

various modes available eg. Dividend / buy-back/

capital reduction

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Base Erosion & Profit Shifting (BEPS)

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BEPS – Key Action Plans that could have an Impact on M&A Transactions

3514-09-2017

Action Plan Impact on M&A

Action Plan 2Neutralise the effects of hybrid mismatch arrangement (i.e. hybrid instruments / entities - not be used for undue tax benefits)

Can reduce the overall value of a transaction, tax credits may be impacted

Action Plan 3 Strengthen Controlled Foreign Company Rules (similar to POEM rules under ITA)

Structures involving incorporation of a foreign low-taxed subsidiary – a difficult planning

Action Plan 4Limit base erosion via interest deductions & other financial payments

Reduces the value assessed from financing transactions / increases tax cost

Action Plan 5Countering harmful tax practice more effectively, taking into account transparency and substance

Recommends nexus approach wherein substantial activity is to be used as a criterion to tax profits arising from intellectual property (IP). Structures using preferential IP regimes to get affected.

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Action Plan Impact on M&A

Action Plan 6 - Preventing Treaty Abuse(Denies Treaty Benefit – where one of the principal purpose of the transaction or arrangement is to obtain benefit)

Could lead to increased cost of establishing operating structures in traditional tax heavens and low-tax holding

Action Plan 7 Prevent artificial avoidance of PE status

M&A structuring to consider Business models to get affected

3614-09-2017

BEPS – Key Action Plans that could have an Impact on M&A Transactions

BEPS and GAAR measures to impact every aspect of M&A transaction right from Due diligence, Structuring, Valuations along with

documentations and reporting.

Existing structures also need a re-examination!!

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3814-09-2017

• Stamp Duty Implications

• GST Implications and carry forward of input credits

• Approval from Competition Commission, if applicable

• Exchange Control Regulations / FEMA

• SEBI Regulations and Take over code for listed entities

• Accounting Implications

• Valuation

The contents of this presentation are intended for general marketing and informative purposes only and should not be construed to becomplete. This presentation may contain information other than our services and credentials. Such information should neither beconsidered as an opinion or advice nor be relied upon as being comprehensive and accurate. We accept no liability or responsibility to anyperson for any loss or damage incurred by relying on such information. This presentation may contain proprietary, confidential or legallyprivileged information and any unauthorised reproduction, misuse or disclosure of its contents is strictly prohibited and will be unlawful.

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14 september 2017 · winner of india tax firm of the year 2016 at the asia tax awards. • the new...

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