Direct Tax Code Details

Description
This is a PPT explaining changes proposed in direct tax code in detail.

Direct Taxes Code 2009 Radhakishan Rawal

PwC

Backdrop

• Current law – Income-tax Act, 1961 • Almost five decades old • Over 5000 amendments • New Code in the making for four years

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Stated objectives

• Simplicity • Minimising litigation • Widening the tax base • Eliminating exemptions

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Slide 3

Topics

• Certain specific issues for real estate sector • Corporate and Personal Tax • Taxation of LLPs • Personal Tax • GAAR • Wealth Tax • International tax

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Certain specific issues for real estate sector

Minimum Alternative Tax (MAT)

• Payable on „value of gross assets? and not on „book profits? • Tax Rate

- Banking companies – 0.25% - Other companies – 2%
• No credit allowed in subsequent years
• Multiple level taxation – holding-subsidiary structures
• Levy of MAT @ 2% on “gross assets”; could apply even during construction

phase - No credit for MAT paid; sunk cost that will reduce IRRs

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Commercial Projects

- Lease rentals characterized as House Property income – could result in higher tax outflow for investee companies - Taxable rent to be higher of contractual rent and presumptive rent

- Presumptive Rent - deemed to be 6% of construction cost if rateable value not available - Lump sum deduction reduced from 30% to 20%

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Residential projects

- Revenues from pre sales – Taxable on receipt basis? - Withholding on sale of flats / commercial units? - Deduction for interest in case of self-occupied properties withdrawn

- Exemption on rollover from one house property to another withdrawn

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Slide 8

SEZ projects

- MAT and DDT exemption for SEZ Developers withdrawn - Profit based incentive sought to be replaced with investment based incentive scheme - No incentive for SEZ units

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Real estate investors

• Venture Capital Funds - Pass thru status - Complications under the current law post amendment to section 10(23FB) removed • GAAR provisions - Use of various financial instruments such as convertibles etc. to meet the requirements of the investors and the developers

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Corporate and personal taxation

Taxation of resident companies

Corporate tax Dividend Distribution Tax MAT Capital gains tax

Existing (%)* 30 15 15 varying

Proposed (%)* 25 15 2 / 0.25 on assets 25

* Surcharge and cess as per the relevant Finance Act
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Business Income…

• Income from separate businesses to be computed separately • Income from businesses eligible for incentives to be computed

separately

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…Business Income…

• Sweeping amendments to the scope of taxable profits

- any amount receivable from or in connection with business included • Taxable profits to now include: - Relief in respect of any liability in the nature of loan, deposit, etc - Amount receivable on cessation / termination of any business agreement • Profit on sale of business capital assets or on slump sale - taxed as business income and not capital gains

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…Business Income…

• Deductions allowable only under three classes:

- Operating expenditure; - Permitted Finance Charges; and - Capital Allowances • Losses incidental to business – selectively covered

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Deferred revenue expenditure

• Specific Deferred Revenue Expenditure eligible for capital

allowance Block of Assets Depreciation Rate (%) Non-compete fees 25 Premium on obtaining assets on lease / rent 25 VRS expenditure 25 Business re-organisation expenditure 25 Expenditure on prospecting mineral or 15 development of mine / other natural deposit of any mineral
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Capital Allowances

• Broadly similar to depreciation and similar allowances

• 150% weighted deduction for in-house scientific R&D

expenditure; extended to all industries
• Loss upon sale of entire block of assets to be ignored

- Depreciation on block to continue

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Minimum Alternative Tax („MAT?)

• Payable on „value of gross assets? and not on „book profits? • Tax Rate

- Banking companies – 0.25% - Other companies – 2%
• No credit allowed in subsequent years • Multiple level taxation – holding-subsidiary structures

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Dividend Distribution Tax

• DDT extended to all “dividends” • Dividend distributed to specified pass-through entities exempt

from DDT
• DDT exemption for SEZ developers discontinued

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Capital Gains…

• Distinction between long-term and short-term gains removed
• Capital gains taxable at normal rates • Gains on transfer of business capital assets taxable as

business income
• Other capital assets referred to as „Investment Assets? • Securities Transaction Tax proposed to be abolished

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…Capital Gains

• Indexation available only for assets held for one full financial

year
• Indexation benefit now available for bonds and debentures

• Indexation benefit now available to non-residents

- Adjustment for exchange fluctuation no longer available
• Substitution of cost by fair market value

- Base date shifted from 1.4.1981 to 1.4.2000
• Cost of acquisition of asset deemed to be “nil” if not

determinable

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Tax incentives…

• Profit-based tax incentives sought to be discontinued • Expenditure / Investment-based incentive scheme introduced • Infrastructure Projects including development of Special

Economic Zones (“SEZ”) under new scheme
• Export-based Incentives such as for units in Software

Technology Parks or SEZs to be discontinued
• Selective grandfathering

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…Tax incentives

• Eligible businesses entitled to following additional deductions:

- Expenditure on purchase, lease or rental of land or land rights
- Capital expenditure on most assets - Expenditure incurred before commencement of business
• Each eligible business to be treated as separate business

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Grandfathering of existing incentives

• Following incentives continued under the Code: - Sec 80-IA – Profits from Infrastructure business - Sec 80-IAB – Profits earned by SEZ developer - Sec 80-IB – Profits from various businesses covered therein - Sec 80-IC – Profits from undertakings in the North-East - Sec 80-ID – Profits from business of hotels / convention centres in specified areas - Sec 80-IE – Profits from undertakings in the North-East - Sec 80JJA – Profits from business of collecting and processing biodegradable waste • No specific provisions for grandfathering of SEZ units eligible

for tax holiday under section 10AA
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Carry forward of losses

• No distinction between long term and short term capital losses
• Loss of a specified business / special source allowable only

against subsequent years? profits of the same business / source
• Losses allowed to be carried forward indefinitely • Entire losses including previous years? losses lapse if return not

filed by due date

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Set-off and carry forward of losses
Business loss, loss from house property or ‘residuary’ losses
Income from employment, house property, Business income, residuary income, incl. capital gains

Capital Loss

Capital gains

Losses from a Special Source

Income from the same Special Source

• Set-off in same or subsequent years • Discussion paper talks of ring-fencing losses from speculative business -

no corresponding provisions in Code
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Taxation of LLPs

Taxation of LLPs

• LLPs, Partnership Firms and AoP / BoI treated as “unincorporated bodies”

and taxed as separate entities
• Applicable tax rate 30% (no MAT, no tax on cash distributions) • Partner?s share not taxed in his hands • In case of change in constitution because of retirement, death etc., losses to

the extent of the share of the retiring / deceased partner cannot be carried forward
• Salaries, bonuses, commissions to working partners and interest to all

partners fully deductible

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Personal Taxation

Tax rates for an individuals

Existing Income Slab (INR) Up to 1,60,000 1,60,001 to 3,00,000 3,00,001 to 5,00,000 Above 5,00,000

Tax Rate* Nil 10% 20% 30%

Proposed Income Slab (INR) Up to 1,60,000 1,60,001 to 10,00,000 10,00,001 to 25,00,000 Above 25,00,000

Tax Rate Nil 10% 20% 30%

*Currently education cess is levied at 3% of the tax amount.

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Deductions for savings

• Restricted to maximum of Rs. 300,000 per year • Amount deposited in accounts with permitted intermediaries

• Withdrawals not taxable if rolled over into another account
• Withdrawals from such accounts taxable

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Taxation of savings

EXISTING
Taxability of Qualifying Investments at present

PROPOSED
Taxability of Qualifying Investments as per Code

On Investment

Accretion

On withdrawal

On Investment

Accretion

On withdrawal

Exempt upto Rs. 100,000

Exempt

Exempt

Exempt upto Rs. 300,000

Exempt

Taxable may result in double taxation

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Roll-over provisions for capital gains…

• Roll-over available for re-investment of sale proceeds • Roll-over available only to individuals/HUFs

• Investment to be made in new asset within

- one year before or - three years from the end of the financial year in which transfer took place • If new asset not acquired before the end of the financial year - Sale proceeds to be deposited in Capital Gains Deposit Scheme

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…Roll-over provisions for capital gains

• Qualifying new assets

- Agricultural land – in case of gain on transfer of agricultural land - Residential house – in case of gain on transfer of any asset - Deposit in Capital Gains Saving Scheme (CGSS) – in case of gain on transfer of any asset • Any withdrawal from CGSS is liable to tax under the head income from residuary sources in the year of withdrawal

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Tax Deduction at Source

• TDS on payments for purchase of goods?

• No ability to seek lower rate of TDS?
• No time limit for completion of TDS assessment

- Time limits were recently introduced

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General AntiAvoidance Rules („GAAR?)

General Anti-Avoidance Rules…

• Empowers the Commissioner of Income-tax („CIT?) to declare an arrangement impermissible

- if the arrangement has been entered with the objective of obtaining tax benefit and, inter alia, lacks commercial substance or misuses the provisions of the Code • The CIT may amend, disregard or re-characterise the arrangement
• Onus on the tax payer to demonstrate that obtaining tax benefit was not the main purpose of the arrangement • Applicable to residents as well as non-residents
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…General Anti-Avoidance Rules

• GAAR provisions are highly subjective • Sweeping powers to tax department • Whether tax planning permissible

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Slide 38

Wealth Tax

Wealth Tax

• Individuals, HUFs and Private Discretionary Trusts liable to • •




wealth tax Wealth tax abolished for companies Rate of wealth tax reduced from 1% to 0.25% Exemption limit enhanced from Rs. 30 Lakhs to Rs. 50 Crores One house or plot of land acquired or constructed before April 1, 2000 exempt

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Slide 40

International tax

Key changes in a nutshell
Positive Lower tax rates but, 2% MAT Introduction of APA and safe harbour rules Indefinite carry forward of business and capital losses Negative Circumstantial

Introduction of sweeping Changes in capital gains General Anti Avoidance Rules legislation Treaty override provisions Increase in withholding tax rates Residence status of foreign companies

MAT

Similar issues for Indian subsidiaries of foreign companies

Treaty override
• For “determining the relationship between … a treaty and this code … the provision which is later in point of time shall prevail” • Principle of beneficial interpretation between the domestic law and tax treaty no longer applicable? • Furnishing of tax residency certificate mandatory for claiming benefits under the applicable tax treaty • GAAR to override applicable tax treaties?
80 existing tax treaties overridden? – Long-standing principle of beneficial choice overturned?
Slide 43

Overview of tax rates

Existing (%) Corporate tax Branch Profits Tax Capital gains tax Royalty/Fees for Technical Services (“FTS”)
* Surcharge and cess as per the relevant Finance Act

Proposed (%)* 25 15 30 20

40 Various 10.56

Slide 44

Overview of branch profits tax

• Branch profits tax (15%) introduced on branches of foreign companies • Illustration INR Branch profits in India 100 Less : Corporate tax at 25% 25 Net profits after corporate tax 75 Less : Branch profits tax at 15% 11.25 Net profits after branch profit tax 63.75 Effective tax rate – 36.25%
Slide 45

Change in residency test for foreign companies
Provision Current Foreign companies resident in India only if controlled and managed wholly in India during the year Threshold lowered to wholly or partly managed and controlled from India at any time during the year Implication Non-India income not liable to tax in India

Proposed

Non-India income exposed to Indian tax

Intent to hit subsidiaries of Indian MNCs? Result: (unintended?) adverse consequences for certain foreign companies
Slide 46

Thank you.

Radhakishan Rawal

Associate Director, PwC
[email protected] Tel : 022 6689 1110
© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the network of member firms of PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity. *connectedthinking is a trademark of PricewaterhouseCoopers LLP (US).

PwC



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