Budget PLUS 2013

EY Tax Alert - Financial Services

Budget PLUS 2013

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Budget PLUS 2013

Introduction This alert summarizes certain significant tax proposals contained in the Finance Bill, 2013 (Bill) and policy announcements, made by the Finance Minister, Mr P Chidambaram during the Budget 2013-14 speech relevant to the financial services sector. The policy pronouncements made by the Finance Minister are expected to be implemented by the Government through legislative announcements in the ensuing months. The Bill will be discussed in the Parliament before it is enacted and is subject to any amendments that may be made pursuant to these discussions. The direct tax proposals discussed in this memorandum are effective from the tax year commencing on 1 April 2013, unless otherwise specified.

Key Policy Initiatives Some of the key initiatives announced by the Finance Minister as a part of his budget speech are summarized below: Financial sector Initiatives proposed to streamline the financial sector laws, rules and regulations as follows:

► It has been proposed to constitute a

Standing Council of Experts to analyse the international competitiveness of the Indian financial sector.

► Recommendations provided in the report presented by the Financial Sector Legislative Reforms Commission will be examined to ensure that the financial sector is well-regulated, efficient and internationally competitive.

Capital markets

Various proposals relating to capital markets have been finalized in consultation with the Securities and Exchange Board of India (SEBI) as follows: ► Depository participants will be eligible to

register different classes of portfolio investors, subject to compliance with Know Your Customer (KYC) guidelines.

► SEBI to simplify procedures and prescribe uniform registration and other norms for entry of foreign portfolio investors.

► SEBI to converge different KYC norms and adopt a risk-based approach to KYC to make it easier for foreign investors such as central banks, sovereign wealth funds, university funds, pension funds etc to invest in India.

► Foreign Direct Investment (FDI) and investment under the Foreign Institutional Investor (FII) route to be distinguished based on the following criteria:

► Investment of 10% or less in a company to

be regarded as investment by a FII; ► Investment of more than 10% to be treated

as FDI. A committee will be constituted to examine the application of the above principle and to work out details expeditiously.

► FIIs will be permitted to participate in the exchange traded currency derivative segment to the extent of their Indian rupee exposure in India.

► FIIs will be permitted to use their investment in corporate bonds and Government securities as collateral to meet their margin requirements.

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► SEBI to prescribe requirements for angel investor pools by which they can be recognised as Category I Alternative Investment Fund Venture Capital Funds.

► Stock exchanges will be allowed to introduce a dedicated debt segment on the exchanges. Insurance companies, provident funds and pension funds will be permitted to trade directly in the debt segment with the approval of the sectoral regulator.

► Mutual fund distributors will be allowed to become members in the mutual fund segment of stock exchanges to leverage on the stock exchange network to improve their reach and distribution.

► The list of eligible securities in which Pension Funds and Provident Funds may invest will be enlarged to include exchange traded funds, debt mutual funds and asset backed securities.

Banking

► Public sector banks will be further capitalised by an amount of approximately ` 265 billion to be infused by 31 March 2014. Steps will also be taken to ensure that they meet the Basel III Regulations.

► Measures will be adopted to bring all banks on the core banking solution and on electronic payment systems (NEFT and RTGS) by 31 December 2013.

► It has been proposed to set up India’s first Women’s Bank with an initial capital of ` 10 billion as a public sector bank by October 2013. The bank will lend mostly to women and women-run businesses and predominantly employ women employees.

Insurance

► Endeavour to pass the following bills in the current session of the Parliament:

► The Insurance Laws (Amendment) Bill, 2008;

► The Pension Fund Regulatory and Development Authority Bill, 2011.

► To increase penetration of insurance, life

and general, the following key proposals have been finalised in consultation with the Insurance Regulatory and Development Authority (IRDA):

► Insurance companies empowered to open

branches in Tier II cities and below without prior approval of IRDA;

► All towns of India with a population of 10,000 or more to have an office of Life Insurance Corporation of India and an office of at least one public sector general insurance company;

► Banking correspondents to be allowed to sell micro-insurance products;

► Banks to be permitted to act as insurance brokers.

Tax reforms

► The Direct Taxes Code (DTC) to be a new

code and not an amended version of the Income-tax Act, 1961 (Act) but be based on best international practices. The DTC Bill is proposed to be brought back before the Parliament in the current Parliamentary session.

► Rules for safe harbours to be issued after examining the last report of the Rangachary Committee, expected in March 2013.

► Tax Administration Reform Commission proposed to be set up to review the application of tax policies and tax laws.

Other key initiatives

► To ensure that ‘Doing business in India’ is viewed as being easy, friendly and mutually beneficial, communication of policies to be improved to remove any

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apprehension or distrust in the minds of investors, including fears about undue regulatory burden or application of tax laws.

► Various steps taken/ proposed to be taken

to increase investment in the infrastructure sector.

DIRECT TAXES

Tax rates Basic tax rates The basic rates for corporate tax, minimum alternative tax and dividend distribution tax (DDT) remain unchanged for both domestic and foreign companies. Special rates The Bill proposes to substitute the tax rate on the income in the nature of Royalty and Fees for Technical Services arising in the hands of a non-resident from the applicable rates [10% applies to agreements entered after 1 June 2005; a higher rate for earlier agreements] with 25%. Where the non-resident is eligible to claim benefits under the double taxation avoidance agreement (DTAA) between India and country of which the recipient is a resident, the lower rate, if any, under the DTAA would apply. Surcharge ► No surcharge is leviable where the income

does not exceed ` 10 million irrespective of the category and residential status of the taxpayer.

► In case of non-corporate taxpayers (whether resident or not), a surcharge of 10% is proposed where the income exceeds ` 10 million. (Currently, no surcharge is payable by non-corporate taxpayers.)

► In case of corporate taxpayers, the current surcharge rate of 2% (for foreign companies) and 5% (for domestic companies) remains unchanged where income exceeds ` 10 million but does not exceed ` 100 million. Where the income exceeds ` 100 million, the surcharge rates are proposed to be increased to 5% (for foreign companies) and 10% (for domestic companies).

► Surcharge rate on DDT, distribution tax on income payable by mutual funds, distribution tax on buy-back of shares (proposed by the Bill), distribution tax on income distributed by securitisation trusts (proposed by the Bill) to be levied at a uniform rate of 10% (on the rate), irrespective of the category of the investor.

Education cess Education cess to continue to be levied at the rate of 3% on the amount of tax computed, inclusive of surcharge, in all cases. Mutual funds The Bill proposes to increase the tax rate on income distributed by mutual funds to an individual or a Hindu Undivided Family (HUF) from 12.5% or 25% (depending upon the nature of fund) to a uniform rate of 25% for all funds other than equity oriented mutual funds.

Particulars Money Market Mutual

Funds/ Liquid Funds

Other Funds (not being

equity oriented

fund) Current rates

Individuals /HUFs 27.038% 13.519%

Others 32.445% 32.445%

1 April 2013 – 31 May 2013 Individuals /HUFs 28.325% 14.163%

Others 33.99% 33.99%

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From 1 June 2013

Individuals /HUFs 28.325% 28.325%

Others 33.99% 33.99%

The Bill proposes a tax rate on income distributed by a mutual fund under an Infrastructure Debt Fund scheme to a non-resident investor of 5.665%. This rate will be effective from 1 June 2013. Securities Transaction Tax (STT) The Bill proposes to reduce STT1 in taxable securities transactions. The revised rates are as follows:

Nature of taxable securities transaction

Payable by

Existing rate

Proposed Rate

Delivery based purchase of units of an equity oriented fund entered on a recognised stock exchange

Purchaser 0.1% Nil

Delivery based sale of units of an equity oriented fund entered on a recognised stock exchange

Seller 0.1% 0.001%

Sale of a futures in securities

Seller 0.017% 0.01%

Sale of a unit of an equity oriented fund to the mutual fund

Seller 0.25% 0.001%

Commodity Transaction Tax (CTT) The Bill proposes to introduce a new tax called CTT. CTT at the rate of 0.01% is proposed to be levied on the seller on sale of commodity

1 This amendment will take effect from 1 June 2013

derivate (other than agricultural commodities), entered on a recognized association.

Securitisation Trusts The Bill proposes to introduce special provisions relating to taxation of income of securitisation entities, set up as trusts and distribution of income by them to the investors. Securitisation trusts have been defined to mean a trust being a: ► ‘Specified purpose distinct entity’

regulated under the SEBI (Public Offer and listing of Securitized Debt Instruments) Regulations, 2008; and

► ‘Special Purpose Vehicle’ regulated by the guidelines on securitsation of standard assets issued by the Reserve Bank of India.

Taxability of securitisation trusts and investors therein

► The Bill proposes that the income of a

securitisation trust from the activity of securitisation shall be exempt from tax. Further, it is also proposed that the income received by the investors from the securitisation trust shall be exempt from tax provided that taxes have been paid by the securitisation trust on such distributed income.

Taxability in respect of income distributed by securitisation trusts

► The Bill proposes to levy an additional tax

on the income distributed by securitisation trusts at the rate of 25% for distribution made to individuals and HUFs and at the rate of 30% in other cases. The above rates will be increased by surcharge of 10% and education cess of 3%. However, no additional income-tax would be payable where the income of the investor is not chargeable to tax.

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► The aforesaid amendment is proposed to be applicable in respect of income distributed by securitisation trusts on or after 1 June 2013.

Taxation of Alternative Investment Funds (AIF) ► SEBI had issued SEBI (AIF) Regulations,

2012 on 21 May 2012 which replaced the existing SEBI (Venture Capital Funds) Regulations, 1996.

► The Bill proposes to grant a ‘pass through’ status to a Category I AIF, provided the following conditions are satisfied:

► Atleast 2/3rd of the investible funds are

invested in unlisted equity shares or equity linked instruments of venture capital undertakings (VCU);

► No investment is made by an AIF in a VCU which is an associate company;

► Units/ shares of an AIF are not listed on a recognized stock exchange.

► The existing venture capital funds or

venture capital companies which are regulated by SEBI (Venture Capital Funds) Regulations, 1996 will continue to avail pass through status.

► This amendment is proposed to take effect retrospectively from 1 April 2012.

Increase in percentage limit of eligible premium for life insurance policies ► Presently, an exemption is available for

any sum received under a life insurance policy issued on or after 1 April 2012, in respect of which premium payable for any of the years during the term of the policy does not exceed 10% of the actual capital sum assured.

► Further, a deduction of ` 100,000 is available for premium paid on life insurance policies (other than a deferred annuity scheme) issued on or after 1 April 2012 to the extent of 10% of the actual capital sum assured (subject to the above cap).

► The Bill proposes to increase the limit

from the existing 10% to 15% in respect of insurance policies issued on or after 1 April 2013 for the insurance on the life of any person with disability or severe disability (as prescribed) or suffering from specified diseases or ailments.

Clarification on keyman insurance policy ► Currently, unlike any sum received under

a conventional life insurance policy, any sum received under a keyman insurance policy does not enjoy exemption from the levy of income-tax.

► The Bill proposes that a keyman insurance policy assigned to any person during the term of the policy, with or without any consideration shall continue to be treated as a keyman insurance policy to prevent the taxpayers from misusing the exemption available in respect of any sum received under a conventional life insurance policy.

Deduction for bad debts ► Currently, banks are entitled to deduction

for provision for bad and doubtful debts at the rate of 7.5% (5% in the case of foreign banks) of the gross total income and 10% of the aggregate average advances made by the rural branches. Further, banks are also entitled to deduction for actual bad debts written off to the extent it is in excess of the credit balance in the provision for bad and doubtful debts account.

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► Recently, the Supreme Court of India had held that if the actual write off of debt relates to urban advances, then it should not be set off against the provision for bad and doubtful debts made for rural branches.

► The Bill clarifies that only one account is

made in respect of the provision for bad and doubtful debts and such account relates to all types of advances including advances made by rural branches. Therefore, the amount of deduction in respect of the bad debts actually written off shall be limited to the amount by which such bad debts exceeds the credit balance in the provision for bad and doubtful debts account without any distinction between rural advances and other advances.

Tax residency certificate ► Presently, benefits available under a DTAA

entered into by the Central Government and the Government of any country or specified territory can be claimed by a taxpayer only where a tax residency certificate containing the prescribed particulars, is obtained by a taxpayer.

► The Bill proposes that the tax residency certificate obtained by the taxpayer would be a necessary condition but not a sufficient condition to avail of the benefits under a DTAA.

► This amendment is proposed to take effect

retrospectively from 1 April 2012.

General Anti Avoidance Rule (GAAR) GAAR was introduced by the Finance Act, 2012 to be effective from the financial year 2013-14. Based on the representations received, an Expert Committee was constituted by the Government. Certain recommendations of the Expert Committee

have been accepted by the Government, some of which have resulted in the following key changes in GAAR:

Deferral of the applicability of GAAR ► Applicability of GAAR has been deferred

to financial year 2015-16.

Impermissible avoidance arrangement

► Presently, an arrangement is considered as an ‘Impermissible avoidance arrangement’ if the main purpose or one of its main purposes is to obtain a tax benefit.

► As per the Bill it is proposed that, an arrangement, the main purpose of which is to obtain a tax benefit will be considered as an ‘Impermissible avoidance arrangement’.

Definition of the term ‘tax benefit’ Currently, the term ‘tax benefit’ is defined in an exhaustive manner to mean: ► A reduction or avoidance or deferral of tax

or other amount payable under the Act, including as a result of a DTAA; or

► An increase in a refund of tax and other amount under the Act or as a result of a DTAA; or

► A reduction in total income, including increase in loss.

The Bill proposes to modify the exhaustive definition to an inclusive one without any specific change in the present criteria. Certain factors for determining commercial substance ► Under the Act, while determining whether

or not an arrangement lacks commercial substance, the period or time for which the arrangement (including operations

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therein) exists, payment of taxes and provisions of exit are not considered.

► The Bill proposes to clarify that the above

factors may be relevant, but shall not be sufficient for determining whether or not the arrangement lacks commercial substance.

► Further, the Bill proposes that an

arrangement, which does not have a significant effect upon business risks or net cash flows of any party, apart from a tax benefit, shall be deemed to lack commercial substance.

Onus on the taxpayer ► Under the Act, an arrangement which

results in any tax benefit shall be presumed to have been entered into, or carried out, for the main purpose of obtaining a tax benefit.

► The Bill proposes to put the onus on the

taxpayer for demonstrating that the arrangement is not entered into only for deriving tax benefit.

Constitution/ Powers of the Approving Panel ► The Central Government may constitute

one or more Approving Panel(s) as may be necessary from time to time.

► Under the Act, the Approving Panel (which decides whether an arrangement is impermissible or otherwise) comprises of a minimum of three members being:

► Income-tax authorities not below the rank

of Commissioner; and ► An officer of the Indian legal service not

below the rank of Joint Secretary to the Government of India.

► The Bill proposes that the Approving Panel

will comprise of three members being:

► A chairperson, who is or has been a Judge of a High Court

► One member of the Indian Revenue Service not below the rank of Chief Commissioner of Income-tax

► One member, who shall be an academician or scholar having special knowledge of matters such as direct taxes, business accounts and international trade practices

Binding nature of directions issued by the Approving Panel ► Under the Act, the directions of the

Approving Panel are binding only on the Assessing Officer.

► As per the Bill it is proposed that the directions of the Approving Panel shall be binding on the taxpayer as well.

► Also, appeal against an order passed pursuant to the directions of the Approving Panel shall lie to the Tribunal.

Accepted recommendations of the Expert Committee not addressed by the Bill Some of the key recommendations of the Expert Committee which were accepted by the Government in January 2013 but have not been formally proposed by the Bill are as follows: ► Grandfathering of investments made

before 30 August 2010.

► The same income not to be taxed twice in the hands of the same taxpayer in the same year or in different assessment years.

► A monetary threshold (` 30 million of tax benefit) in order to attract the provisions of GAAR.

► Only one of GAAR and Specific Anti Avoidance Rules to apply when both of them are in force.

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It is expected that some of these changes could be implemented by way of guidelines to the GAAR provisions.

Tax on distributed income for buy-back of unlisted shares ► Gains arising to a shareholder on buy-back

of shares, ordinarily qualifies as capital gains (where shares are held as capital assets). Where the shareholder is a resident of a country with which India has a DTAA (such as India-Mauritius DTAA), such gains could be exempt from tax in India.

► The Bill proposes to levy an additional income-tax on buy-back of shares (of unlisted companies) at the rate of 20% (plus surcharge of 10% and education cess of 3%) on the distributed income (i.e. consideration paid by the company on buy-back of shares as reduced by the amount received by the company for issue of such shares).

► Where the company is liable to pay the said distribution tax on buy-back of shares, income arising to the shareholders in respect of such buy-back would be exempt from tax.

► This amendment will take effect from 1 June 2013.

Interest income from long term infrastructure bonds

► Presently, interest paid by an Indian

company to a non-resident, in respect of approved borrowings made (during the period 1 July 2012 to 30 June 2015) in foreign currency from sources outside India (under a loan agreement or on issue of long term infrastructure bonds) is

taxable at a concessional rate of 5% (plus applicable surcharge and education cess).

► In order to facilitate subscription by a non-

resident in long term infrastructure bonds issued by an Indian company (rupee denominated bonds), the Bill proposes to extend the benefit of the concessional rate where:

► the non-resident deposits foreign currency

in a designated bank account; and ► such money, after conversion, is used for

subscription to a rupee denominated long term infrastructure bond issue of an Indian company.

► This amendment will take effect from

1 June 2013.

Concessional rate for dividends received from foreign subsidiary ► Currently, any amount received by an

Indian company in respect of dividends declared, distributed or paid by a specified foreign company during the financial year 2011-12 and 2012-13 is subject to tax at the rate of 15% in the hands of the Indian company. Specified foreign company means a foreign company in which the Indian company holds 26% or more of equity share capital of the former company.

► The Bill proposes to extend the applicability of the aforesaid provision in respect of dividends declared, distributed or paid for the financial year 2013-14.

Removal of the cascading effect of DDT

► In order to encourage remittances of

dividends to a domestic company by its foreign subsidiary, the Bill proposes that

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no DDT will be payable on the dividend distributed by the domestic company to its shareholders during the financial year (i.e. financial year 2013-14) to the extent of dividend, received during the same financial year, from the foreign subsidiary in respect of which tax is payable by the domestic company at the rate of 15%.

► For this purpose, a company is a

subsidiary of another company if such other company holds more than 50% of the equity share capital of the former company.

► This amendment is proposed to take effect

from 1 June 2013 and will only be applicable for financial year 2013-14.

INDIRECT TAXES

Service tax ► No change in effective service tax rate of

12.36%.

► Minimum changes made to the levy and procedural provisions.

► A 20% increase in value liable to service tax for construction of specified properties.

► Service Tax Voluntary Compliance Encouragement Scheme, 2013, an amnesty scheme, is introduced to encourage voluntary compliance by taxpayers.

► Provisions of Advance ruling extended to

resident public limited companies.

► More stringent penalties to apply for offences liable for prosecution.

► Appellate Tribunal may extend the period of stay order not exceeding 185 days where the delay in disposing of the appeal is not attributable to appellant. Stay order

shall stand vacated, if the appeal is not disposed off within the total period of 365 days.

► New provision to prescribe penalty on

directors and officials for specified wilful actions up to ` 100,000.

► Power granted to Commissioner to order the arrest for specified offences.

Customs ► Peak rate of basic customs duty remains

unchanged.

► Powers granted to customs officers for recovery of outstanding duties of a defaulter from any other person including banks / insurance companies who holds money on behalf of the defaulter.

Excise ► No change in the basic excise duty rate of

12%.

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Comments

While the Budget has proposed a number of favorable policy initiatives and forward looking ideas for the financial services sector, contrary to the expectations, the Bill has not addressed some of the following key areas: • Implementation of the

recommendations of the Expert Committee constituted to examine the ‘indirect transfer’ provisions;

• Availability of concessional rate of 10% (introduced by the Finance Act, 2012) on long term capital gains earned by non-resident investors arising on transfer of securities issued by private companies;

• Grandfathering of the investments made before 30 August 2010 from GAAR provisions, as was announced by the Finance Minister.

Presumably, some of these may get clarified through circulars, guidelines, in due course as and when internal consultations are concluded.

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