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TAX
KPMG IN INDIA
Direct Taxes Code Bill 2010
September 2010
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, a
Swiss cooperative. All rights reserved.
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Agenda
1 Background
2 Personal Tax
3 Capital Gains
4 Corporate Tax rates
5 Overview Sources of Income
6 Classification of Assets
7 Business Income
8 MAT
9 SEZs, SEZ units & Infrastructure Sector
10 DDT Credit
11 International Taxation
12 Transfer Pricing and Wealth Tax
13 Hits and Misses / Key Focus Areas
2010 KPMG, an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (KPMG International), aSwiss entity. All rights reserved.
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Background
DTC 2009 unveiled in August 2009
The Government received over 1,600 representations on DTC 2009
RDP released in June 2010 on 11 specific issues
DTC 2010 tabled in the Lok Sabha on 30 August 2010
DTC 2010 to cost the Exchequer revenue loss of INR 531,720 Million on reduced rates
After clearance from the Parliamentary Standing Committee, the Bill may be passed in
the Winter Session
The DTC 2010 to be effective from FY commencing 1 April 2012
319 Sections and 22 Schedules in DTC 2010 vis--vis
298 Sections and 14 Schedules in the ITA
Simplified Legislation ?
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Existing Slabs
(ITA)
Proposed Slabs
(DTC 2010)
Tax Rate
(percent)
Upto INR 160,000 Upto INR 200,000 Nil
INR 160,001 to 500,000 INR 200,001 to 500,000 10
INR 500,001 to 800,000 INR 500,001 to 1,000,00020
Above INR 800,000 Above INR 1,000,000 30
Personal Tax - Rates of Income Tax
Tax Liability / Income (INR) 3,000,000 2,000,000 1,000,000
Savings in percent income
ITA vis--vis DTC 2010
1.55 1.88 2.86
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Gain on transfer of Equity Shares / Units ofEquity Oriented Fund
DTC 2009 DTC 2010
LTCG No STT / Taxable @25 percent STT / CG Exempt
STCG No STT / Taxable @25 percent
STT / Only 50percent gains are
taxable @ 30percent
Capital Gains
LTCA : Period of holding of shares / units
One year from the date of acquisition or
One year from the end of the FY in which the shares / units are purchased ?
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Category ITA (Headline Rates) DTC 2010
Income Tax - Indian Company 30 percent 30 percent
Income tax - ForeignCompany
40 percent
30 percent
Additional branch profit tax - 15percent
MAT 18 percent 20 percent
DDT 15 percent 15 percent
Income distributed by mutualfund to unit holders of equityoriented Funds
Not applicable 5 percent of income distributed
Income distributed by lifeinsurance companies to policyholders of equity oriented lifeinsurance Schemes
Not applicable 5 percent of income distributed
Corporate Tax Rates
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Income
Pari materia with DTC 2009
Overview Sources of Income
Special Sources
Non-Resident
Investment Income (Interest,
Dividend, Capital Gains, etc.)
Royalty and Fees for TechnicalServices, etc.
Non-Resident Sportsman / SportsAssociation / Institution
Winning from lottery, race, horse race,any game or betting, etc. for allAssesses
Ordinary Sources
Other than Special Sources:
Income from Employment
Income from House Property
Income from Business
Capital Gains
Income from Residuary Sources
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Business Trading Assets Business Capital Assets Investment Assets
Stock-in-trade
Raw materials
Consumable stores
Tangible capital assets
Intangible capital assets
Self-generated assets
Other capital assetsexcept land
Any capital asset other than
business capital asset
Security held by FIIs
Undertaking / Divisionof a business
TaxableasBusinessIncome T
axa
bleasCapitalGains
Classification of Assets
Impact / Issues
Slump sale to be taxed as capital gains and not business income, unlike DTC 2009
Transfer of Security held by FIIs chargeable to Capital gains and not Income fromBusiness
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Sale of carbon credits to be taxable as business income : Impact on earlier years ?
Expenditure to be allowed in the year of payment of TDS Two years limitation under
DTC 2009 dropped
Weighted deduction for in-house scientific R&D facility increased to 200 percent in line
with ITA
Non-moving creditors beyond five years to be treated as taxable business income as
against three years in DTC 2009
Deduction for specified deferred revenue expenditure to be allowed on straight-line
basis over 6 / 10 years as against allowance on WDV basis @ 25 percent / 15 percent
as under DTC 2009
Business Income
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Asset based levy in DTC 2009 substituted with Book Profits based levy as under ITA
SEZ developers / SEZ Units no longer exempt from MAT
Headline Rate increased from 18 percent to 20 percent
MAT Credit : Similar Mechanism as under ITA
Carry forward of MAT credit upto 15 years as against 10 years in the ITA
MAT credit to lapse in case of conversion of a private company or an unlisted public
company into a limited liability partnership
MAT
Impact / Issues
No specific provision for grandfathering of unutilized MAT credit carried forward from ITA
No provision for carry forward of MAT credit in case of business reorganisation
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SEZs / SEZ Units
Particulars Incentives to SEZ Developers Incentives to SEZ Units
ITA DTC 2010 ITA DTC 2010
Profit-linkedincentives
Yes irrespective ofdate ofnotification
Yes notifiedup to 31.3.2012
Yes irrespective ofdate ofcommencementof operations
Yes commencementof operations before31.3.2014
(No condition for duedate for notification of
SEZ)Investment-linkedincentives
Not Applicable Yes notifiedon or after01.04.2012
Not Applicable Yes commencementof operations on orafter 01.04.2014
MAT payable No Yes irrespective ofdate ofnotification
No Yes irrespective ofdate ofcommencement ofoperationsDDT payable No Yes
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Investment linked tax incentive retained and extended to
specified hotel, hospital and an SRA vis--vis DTC 2009
No deduction for expenditure incurred on acquisition of
land (including long term lease) Ambiguity resolved
No tax incentives to successor in case of business
reorganisation (brought on par with ITA)
Tax incentives for specified business
Increase in rate for calculating
presumptive income for businessesrelating to oil exploration, shipping
operation, air transport etc.
Actual profits taxable if higher than
presumptive profits
Presumptive taxation (non-residents)
Infrastructure Sector
Impact / Issues
LLPs may be explored for infrastructure facilities
Non-residents falling under presumptive tax regime :
Additional tax outgo
Necessity to maintain books of accounts for Indian operations?
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ITA
DTC 2009
DTC 2010
Same as ITA
Same as ITA, except condition no. 3 deleted
DDT Credit
In computing DDT, amount of dividend declared (INR 100) by a Company (X) to bereduced by dividend received (INR 70) from another Company (Y), if:
1) dividend (INR 70) is received (by X) from a subsidiary (Y)
2) subsidiary (Y) has paid DDT on such dividend (INR 70); and
3) recipient company (X) is not a subsidiary of any other company (Z)
Impact / Issues
X eligible for DDT credit under DTC 2010 unlike ITA, even if X is a subsidiary of Z:
Significant relaxation for intermediate holding companies
Availability of Multi-level DDT credit (DDT on INR 70 paid by Y and set-off by X) flow through toZ for dividends declared by Z?
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CFC provisions introduced
Total income of residents to include income attributable to a CFC
CFC means a foreign company:
that is a Resident of a Territory with lower rate of taxation
whose shares are not traded on any stock exchange recognized by such Territory
over whom person(s) resident in India exercise control
that is not engaged in active trade or business
has specified income exceeding INR 2.5 million
Lower rate of taxation, exercise control, active trade or business, specified incomedefined
Active trade or business interalia not to include income from sale of goods or supply of
services to any associated enterprise
International Taxation CFC (1/2)
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Income attributable to a CFC to be computed as per Specified Formula
Resident assessee to furnish details of investments and interest in entities outside India
Wealth tax to be levied on resident assessee
International Taxation CFC (2/2)
Impact / Issues
Evaluate impact on overseas investments / intra-group supply chain arrangements
DTC 2010 follows a Global and Entity Approach in taxing CFC Income either All or
None of the CFC income will be attributable
Applicability of CFC regime to downstream investment subsidiaries of overseas operatingcompanies?
Applicability of CFC regime to non-corporate overseas entities?
Computation of profits of the CFC for measuring lower rate of taxation could pose complexitiesCredit / deduction in India for Foreign Taxes paid by CFC?
Gains on sale of CFCs shares to be taxed without offsetting prior years taxes paid due toapplication of CFC
Set-off between profits and losses of different CFCs?
Double taxation on account of applicability of TP and CFC provisions?
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GAARs invoked -Is main purpose
Arrangement of taxbenefit?
(impermissibleavoidance
arrangement)Deemed connected
person as same,etc
Treat the arrangementas void
Disregardaccommodating
parties/ Treat partiesas one and the same
Re-allocate
income, expenses,relief, etc
Disregard/ combine/ re-characterize
the arrangement
Re-characterizeEquity -Debt,
Income, expenses,relief, etc
Rights / Obligationsnot at arms-length
Misuse /Abuse of DTC
Lacks commercial/
economic
substance
Is not for bonafide
purposes
International Taxation GAARs (1/2)
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International Taxation GAARs (2/2)
Impact / Issues
GAARs to override tax treaties: Sustainability of tax treaty protection with Mauritius,
Cyprus, etc. in absence of appropriate substance / commercial rationale, etc.?
GAARs not to be invoked for every arrangement involving tax mitigation (RDP)
To watch out for CBDT guidelines on GAARs
Effectiveness of DRP route for resolving GAARs related disputes
Availability of AAR mechanism?
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DTC 2010
DTC 2009
International Taxation Treaty Override
Restoration of Treaty supremacy over domestic law as under ITA
Limited Treaty Override - Tax Treaty not to have preferential status when
GAAR invoked; or
CFC triggered; or
BPT levied
No preferential treatment between DTC or the Tax Treaty
Provision which is later in point of time to prevail
Impact / Issues
Deeming provisions for non-residents: Scope enlarged in DTC 2010
Treaties to override deeming provisions
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ITA
DTC 2009
DTC 2010
International Taxation- Tax Residency for Foreign Companies
Control and management of affairs situated wholly in India
Control and management of affairs situated wholly or partly in India, at any time in
the FY
Place of effective management (POEM) situated in India, at any time in the FY
place of effective management of the company means -
the place where the board of directors of the company or its executivedirectors, make their decisions; or
in a case where the board of directors routinely approve the commercial andstrategic decisions made by the executive directors or officers, the place
where such executive directors or officers perform their functions.
Impact / Issues
Residency for non-corporate entities continues to be based on control and management test
Expression at any time very wide
Meaning of the expressions routinely / commercial and strategic decisions
Multiple POEMs in India and abroad : Application of tie-breaker test in tax-treaty?
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DTC 2010
Income deemed to accrue / arise, directly or indirectly, in India from the transfer of a capitalasset situated in India (Same as ITA)
However, following shall be not be deemed to accrue / arise in India: (New)
Income from transfer, outside India, of shares or interest in a foreign company unless FMV
of assets in India (owned directly or indirectly by the company) represent atleast 50 percent
of the FMV of all assets owned by the foreign company50 percent test to be applied at any time during the 12 months prior to transfer (New)
Tax on income computed under DTC 2010 to be pro-rated based on FMV proportion of India
assets/ total assets of foreign company (New)
DTC 2009Income deemed to accrue/arise, directly or indirectly, in India from the transfer, directly orindirectly, of a capital asset situated in India
International Taxation- Transfer of Assets by non-residents
Impact / Issues
Overseas transfer of assets / shares (with underlying economic interest in India) whether taxable?
Meaning of the expressions interest in a foreign company / owned directly and indirectly by theCompany
Exclusions applicable only for shares or interest in a foreign company and not to intangible assets liketrademark
Guidelines awaited on FMV methodology, which are critical in determining applicability of this provision
Provision can be overridden by a favourable tax treaty
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PE defined : Relevant for Business Connection and BPT
PE includes :
Fixed place PE,
Service PE (no time threshold specified),
Construction / Installation / Assembly / Supervisory PE (no time threshold specified),
Substantial Equipment PE (no time threshold specified) and
Agency PE (excludes independent agents)
International Taxation- Permanent Establishment
Impact / Issues
Non-specification of time thresholds : Impact thereof
No exclusions for preparatory and auxiliary activities
No definition for Independent Agent
Provision of Services in India resulting in Service PE : Taxability on a gross basis vs. net basis
PE definition in Treaties to over-ride Business Connection test
BPT not subject to treaty protection; hence, treaty definition of PE not relevant for BPT
Chargeability to BPT in a situation where PE exists under the DTC 2010 but no PE under treaty
(and consequently no liability to Income tax) ?
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APA regime continues as provided under DTC 2009
Audit Process
Proposal to select cases based on Risk dropped
TPO no longer required to issue show-cause before making adjustment
AE definition generally aligned with ITA; some broadening
Location - Enterprises in any specific location (to be prescribed)
Provision of Services - where amount / conditions are influenced by other
enterprise
Shareholding, loans, nomination of directors etc. aligned with ITA
Transfer Pricing
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Every person (other than a NPO) will be liable to pay wealth-tax
Wealth-tax payable at the rate of 1 percent on net wealth exceeding INR 10 Million (as
against INR 500 Million proposed in the DTC 2009)
Specified assets for computing net wealth in line with WTA with certain additions i.e.:
Archaeological collections, drawings, paintings, sculptures or any other work of art
Watches with a value in excess of INR 50,000
Bank deposits outside India, in case of individuals and HUFs, and in any other case,
any such deposits not recorded in the books of account
Interest in a foreign trust or any other body located outside India other than a
foreign company;
Any equity or preference shares held by a resident in a CFC
Cash in hand in excess of INR 200,000 in the case of an individual and HUF
Valuation guidelines to be notified
Wealth Tax
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Exemption from LTCG on listed shares
MAT leviable on Book Profits as against
Gross Assets
Income Tax Holiday for SEZ / SEZ units
partially extended
Supremacy of Tax Treaty in most cases
Beneficial Tax regime for LLPs continues
APA regime
Settlement Commission
Continuity of E-E-E
MAT for SEZs / SEZ Units
DDT for SEZs
Wide-sweep of GAARs retained
CFC Regulations
Non-Rationalisation of DRP regime
Uncertainty in taxability of cross-border
transactions / overseas M&As
Expansion of Wealth Tax net
HITS
MISSES
Hits and Misses
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Key Focus Areas for India Inc / MNCs
Representation before Parliamentary Standing Committee
CFC Regime : Evaluating impact on outbound investments / acquisitions by India Inc.
Inbound Investments through Mauritius / Cyprus etc: Evaluating substance / migration?
Preparing for APAs
Evaluate withholding tax implications on cross border transactions
Taxability of overseas Mergers and Acquisitions
Life beyond Tax Holiday: Assess impact
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AAR Authority for Advance Rulings
AE Associated Enterprise
APA Advance Pricing Agreement
BPT Branch Profits Tax
CFC Controlled Foreign Companies
CBDT Central Board of Direct Taxes
CG Capital Gains
DTC 2009 Direct Taxes Code Bill 2009
DTC 2010 Direct Taxes Code Bill 2010
DRP Dispute Resolution Panel
DDT Dividend Distribution Tax
E-E-E Exempt-Exempt-Exempt
FII Foreign Institutional Investors
FMV Fair Market Value
FY Financial Year
GAARs General Anti Avoidance Rules
HUF Hindu Undivided Family
ITA Income-tax Act, 1961
LTCA Long-term Capital Asset
Glossary
LTCG Long-term Capital Gain
LLP Limited Liability Partnership
MAT Minimum Alternate Tax
NPO Non Profit Organisation
PE Permanent Establishment
POEM Place of Effective Management
RDP Revised Discussion Paper on Direct Taxes Code
R&D Research & Development
SEZ Special Economic Zone
STCG Short-term Capital Gain
STT Securities Transaction Tax
TDS Tax Deducted at Source
TP Transfer Pricing
TPO Transfer Pricing Officer
WTA Wealth Tax Asset
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Questions
Answers
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Uday VedHead of Tax
KPMG in IndiaTel: +91 22 3090 2130Email: [email protected]
Dinesh KanabarDeputy CEO & Chairman - Tax
KPMG in IndiaTel: +91 22 3090 1661Email: [email protected]
THANK YOU ALL FORYOUR ATTENTION !
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Mumbai
Lodha Excelus, 1st Floor,
Apollo Mills Compound,
N.M. Joshi Marg, Mahalakshmi,
Mumbai 400 011
Tel +9122 39896000
Fax +91 22 39836000
New Delhi
Building No.10, Tower B,
8th Floor, DLF Cyber City,
Phase II
Gurgaon 122002 Haryana
Tel +91 124 3074000
Fax +91 124 2549101
Bangalore
Maruthi InfoTech Centre
11/1 and 12/1, East Wing, II Floor,
Koramangala,Inner Ring Road
Bangalore 560 071
Tel +91 80 3980 6000
Fax +91 80 3980 6999
Hyderabad
8-2-618/2
Reliance Humsafar, 4th Floor
Road No. 11, Banjara HillsHyderabad 500 034
Tel +91 40 6630 5000
Fax +91 40 6630 5299
Chennai
No. 10 Mahatma Gandhi Road,
Nungambakam,
Chennai 600 034
Tel +91 40 3914 5000
Fax +91 40 3914 5999
Kolkata
Infinity Benchmark,
Plot No.G-1, 10th floor,
Block - EP & GP,
Sector - V, Salt Lake City
Kolkata 700091
Tel: +91 33 44034066Fax: +91 33 4403 4199
Pune
703, Godrej Castlemaine,
Bund Garden,
Pune 411 001
Tel +91 20 305 85764/65
Fax +91 20 305 85775
Kochi
4/F, Palal Towers,
M. G. Road,
Ravipuram, Kochi 682016
Tel +91 (484) 302 7000
Fax +91 (484) 302 7001
Chandigarh
SCO 22-23
Ist Floor, Sector 8 C
Madhya Marg
Chandigarh 160019
Tel +91 72 3935 781
Fax +91 72 3935 780
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information,
there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional
advice after a thorough examination of the particular situation.
2010 KPMG I di P t hi d m mb fi m f th KPMG t k f i d d t m mb fi m ffili t d ith KPMG I t ti l C ti (KPMG I t ti l)
www.kpmg.com/in