india watch issue 17
TRANSCRIPT
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India WatchISSUE 17 JULY 2012
In association with
Welcome to the Summer edition of GrantThorntons India Watch, in association with theLondon Stock Exchange
Our guest contributor, Adam Forshyth,
research Director at Arden Partners, highlights
how continued demand for power in India is
driving opportunities for companies with secured
coal stocks and renewable energy capabilities.Lastly, Anshu Khanna, Partner at Walker,
Chandiok & Co, gives us an update on the
international and local concerns on the proposed
General Anti-Avoidance Regulations (GAAR)
and explains how these may affect cross-border
deals, foreign investments into India and domestic
business transactions.
If you would like to discuss any of the matters
arising in this issue or how Grant Thorntons
South Asia group can help you please contact us.
In this issue we highlight that the Grant
Thorntons India Watch Index underperformed
against its peer indices but it remained resilient
over the year. It appears that energy, mining and
related infrastructure companies are taking thebiggest falls.
The second quarter of 2012 saw domestic deal
activity reinforcing the local belief in the India
growth story by clocking up a total of 89 deals,
amounting to USD 1.3 billion. Cross border deal
activity, however, mirrored ongoing global woes
and economic uncertainty, to notch up only USD
5.1 billion worth of deals for the quarter. Private
Equity for the quarter also saw a fall, clocking up
USD 1.8 billion in deal value.
We take a look back over the last 6 months
and review what progress and developmentshave taken place in Indias economy. In the first
three months of 2012 Indias economy grew at
its slowest rate since 2003 with GDP growth of
only 5.3%. For the financial year to March 2012,
Indias real GDP fell to around 6.5%, down from
8.4% in the previous financial year.
Anuj Chande
Partner, Corporate Financeand Head of South Asia Group
Grant Thornton UK LLP
T+44 (0)20 7728 2133
Munesh Khanna
Senior PartnerGrant Thornton India LLP
T+91 22 6626 2600
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Grant Thorntons India WatchIndex remains resilient over theyear despite Indias slower growth
In the second quarter of 2012, it was clear thatinvestor uncertainty in respect to India hadmanifested itself. While the Grant ThorntonIndia Watch index underperformed againstits peer indices in the quarter, the year to dateperformance remains encouraging.
80
90
100
110
120
130
Jun 2012May 2012Apr 2012Mar 2012Feb 2012Jan 2012
GT India Watch ALL
FTSE 100
FTSE AIM ALL-SHARE
GT India Watch smaller caps
FTSE ASEAN
FTSE AIM 100
FTSE AIM UK 50
Source:Thomson Datastream
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India Watch - Issue 17 July 2012Indi
If the figures for our India Watch Small Caps
are taken as representative, a good performanceagainst the FTSE AIM ALL-SHARE and FTSE
AIM 100 can be seen, with the India Smaller
Caps Index closing four and five points ahead
respectively. A few clear winners and losers can
be seen in the index figures for this quarter: we
reported in Q1 that no real sector trends had
emerged and while the biggest rises in this quarter
are fairly diverse, it appears that energy, mining
and related infrastructure companies are taking
the biggest falls.
Clear winners in Q2 come from real estateinvestment, media and support services. DQ
Entertainment performed particularly well,
especially against the backdrop of their recent
history. The animation specialists gained five
points in Q2 after struggling in 2011 to keep costs
under control. This means DQ Entertainment
finish with a year to date index of -5, a good
performance given last years problems. Delivery
of higher profit margins on distribution and the
developments in their IP work have made a big
difference this quarter.
Financial services company EIH continue to
impress, with a solid two-point rise in Q2 and
an encouraging 67-point increase from Jan 2010
to date. Their offering of a diversified Indian
private equity portfolio, with exposure weighted
towards infrastructure and real estate, is the cause
of confidence among their directors that their
underlying portfolio has yet room to mature and
realise further cash distributions.
With a slim two-point rise in Q2 but a healthy
seven-point rise in year to date, real estate
investment company Eredene perhaps reflects thesame confidence in infrastructure investment in
India. As the company continues work to secure
investment in the Ennore Port project a 1.5
million TEUs (twenty foot equivalent units) build
for container shipping, and a recent shareholderdispute over Matheran Realty concludes, Eredene
are set to enter Q3 with great prospects.
Resilience in the sector wasnt shared by
real estate and investment firm HIRCO, whose
32-point fall was approaching that of firms who
had taken the largest hit. While mining specialists
Kolar Gold ended the quarter 37 points down, it
was the energy sector that appears to have borne
the brunt of the fall. Essar Energy continues to
disappoint, with consistent underperformance
that reflects overall poor results since its entry tothe index in Jan 2011. Biofuel producer Nandan
Cleantec and power generator OPG Power
Ventures both suffered sharp falls compared
with their year to date, but it was Mytrah
Energy and Oilex that took the greatest shocks,
42 and 62 points down respectively. Mytrahs
announcement to expand total wind assets to
500MW by March 2013, and Oilexs resumption
of studies into prospective wells in Gujarat state,
may well help to increase confidence over the next
two quarters.
Anuj Chande
Partner, Corporate Financeand Head of South Asia Group
Grant Thornton UK LLP
T+44 (0)20 7728 2133
* The India Watch Index
consists of 31 Indiancompanies listed on AIM or
the Main Market (excluding
GDRs). We only consider
companies to be Indian if
they are domiciled in India
and/or foreign companies
holding Indian assets or
Investment companies
with Indian promoters. The
index has been created via
Datastream, a Thomson
Reuters product and is
weighted by Market Value.
To avoid distortion of index
trends, the two largest
market cap entities, Essar
Energy and Vedanta
Resource, are excluded.** Data sourced from
Thomson Reuters.
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April June 2012 M&A dealscape
M&A deal values for Q2 2012 registered an
overall decrease of about 47% from Q2 2011 at
USD 6.32 billion, with the fall being attributable
to a considerable dip in cross border deal activity,
despite sustained momentum in domestic M&A.
Cross border M&A deal values in Q2 2012
fell about 54% vis--vis 2011 levels for the
same quarter. Structurally high food inflation,
high interest rates, slowing GDP, and poor
governance and policy paralysis have contributedto an under-whelming outlook for India for
the short term, causing foreign entities to put
their India investment plans on hold. Similarly,
Changing trends - Domesticdeal momentum continues toscore over cross border activity
Q2 2012 saw domestic deal activity reinforcing local belief in the Indiagrowth story by clocking a total of 89 deals, amounting to USD 1.3 billion, asagainst 86 deals at USD 1 billion for the corresponding quarter in 2011. Crossborder deal activity, however, mirrored ongoing global woes and economicuncertainty, to notch up only USD 5.1 billion worth of deals for the quarteras against USD 11 billion worth of deals for Q2 2011. Private Equity for thequarter also saw a fall, clocking up USD 1.8 billion in deal value, as againstUSD 2.9 billion for the corresponding 2011 quarter.
the continued European Union worries that
spooked investors throughout the quarter, along
with speculation of a Grexit, the spectre of
widespread defaults and volatile stock markets,
could have proved a deterrent, at-least in the near
future, to Indian companies looking to acquire
targets abroad.
Domestic deal activity continued to show
resilience, posting a 26% increase in deal values in
Q2 2012 as compared to Q2 2011 levels.
Q2 Deal Summary Volume Value (USD billion)
Year 2010 2011 2012 2010 2011 2012
Inbound 21 32 41 4.29 6.74 3.61
Outbound 62 53 24 4.63 4.26 1.46
Cross Border 83 85 65 8.92 11.00 5.07
Domestic & Internal Restructuring 114 86 89 2.53 1.00 1.26
M&A 197 171 154 11.45 12.00 6.32
PE 66 120 102 1.39 2.90 1.80
QIP 17 2 1 1.69 0.13 0.00
Grand Total 280 293 257 14.53 15.03 8.12
Deal summary: April - June 2012
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Top M&A deals: Q2 2012
Acquirer Target Sector Domestic/Crossborder USD million
Hongkong and Shanghai
Banking Corp
The Royal Bank of Scotland - retail and
commercial banking businesses in India
Banking and nancial services Inbound 1,895
Piramal Healthcare Decision Resources Group Pharmaceuticals, healthcare and biotech Outbound 680
Mitsui Sumitomo Insurance
Company Limited
Max New York Life Insurance
Company Limited
Banking and nancial services Inbound 530
India Hospitality Corp Adelie Food Holdings Limited FMCG, food and beverage Outbound 350
Sony Pictures Television Multi Screen Media Media, entertainment & publishing Inbound 271
Roquette Freres Riddhi Siddhi Com Processing Private
Limited - Starch business of Riddhi Siddhi
Gluco Biols
FMCG, food and beverage Inbound 190
Ybrant Digital Limited PriceGrabber, LowerMyBil ls,
ClassesUSA.com
IT & ITeS Outbound 175
Bharti Airtel Qualcomm India Pvt. Limited Telecom Domestic 165
Fairfax Financial Holdings
Limited
Thomas Cook - India operations Travel and Tourism Inbound 163
Aditya Birla Nuvo Limited Pantaloon Retail India Limited (PRIL) -
Pantaloon format of business
Retail Domestic 160
M&A sector focus
Banking and financial services (BFSI) contributed
39% of deal activity by value in Q2 2012,
followed by pharma, healthcare and biotech
(12%), FMCG, food and beverage (9%), IT
and ITeS (8%) and media, entertainment and
publishing (6%).
The BFSI sectors performance was spurred
by two cross border deals - Mitsui Sumitomo
strategic stake purchase in Max New York
Life Insurance Ltd for about USD 530 million,and HSBCS deal to buy the Indian retail and
commercial banking businesses of Royal Bank
of Scotland for USD 1,895 million. Factors
such as the extended timelines to obtain branch
licenses from the Reserve Bank of India by
foreign banks, low banking and financial services
penetration in the country and fundamental
growth opportunities in the Indian economy
have made the Indian BFSI sector an avenue for
both domestic consolidation and foreign interest.
However, the sector has also seen some stress in
the form of deteriorating asset quality due to bad
loans to sectors such as aviation, and domestic
and overseas liquidity constraints. It will be
Banking and financialservices [39%]
Pharmaceuticals,healthcare and biotech [12%]
FMCG, food and beverage [9%]
IT & ITeS [8%]
Media, entertainment andpublishing [6%]
Others [26%]
Top M&A sectors: April - June 2012
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interesting to watch how the sector performs in
terms of deal activity in the second half of 2012.The biggest deal in the pharma, healthcare and
biotech sector was Piramal Healthcare Limiteds
acquisition of the US based Decision Resources
Group for approximately USD 680 million. The
impending patent cliff in the US, as well as rising
research costs, lower drug approval rates and
mounting regulatory pressures in the developed
markets have long been considered to fuel Indian
M&A activity in the pharmaceutical sector.
The Indian media, entertainment and
publishing sector has demonstrated growth in the
last few years due to headroom provided by risingdisposable incomes, strong consumption in tier
two and three cities, under-penetration and the
fast-growing new media businesses. It is therefore
not surprising that the sector saw players such
as Eros International Plc and Sony Pictures
Television increasing their stake in Indian entities.
The FMCG, food and beverage sector saw
an interesting deal in India Hospitality Corps
acquisition of Adelie Food Holdings Ltd, a
ready-to-eat food products supplier in the UK,
for a reported USD 350 million, signaling thereadiness of Indian companies to establish a
global presence.
Other sectors such as oil and gas, which
were top performers in Q2 2011, have shown
muted performance in the corresponding 2012
quarter. This could be attributed to the current
policy regime and the failure of some projects to
obtain clearances from several ministries such as
environment and forests, and defence.
Other sectors such as power and aviation are
expected to see heightened deal activity from the
Investor Investee Sector USD million
Morgan Stanley Continuum Wind Energy Power and energy 210
APG - pension fund Lemon Tree Hotels Hospitality 130
Warburg Pincus Future Capital Holdings Banking and nancial services 112
Advent International Corporation CARE Hospital Pharmaceutical, healthcare and biotech 105
TA Associates Omega Healthcare Management
Services BPO unit
IT & ITeS 93
Indivest Pte Limited - Government of
Singapore Investment Corporation
Pte Limited
Marico Limited FMCG, food and beverage 75
Sequoia Capital Global Equities Just Dial Pvt Limited IT & ITeS 61
ChrysCapital Intas Pharmaceuticals Limited Pharmaceutical, healthcare and biotech 56
NYLIM Jacob Ballas Super Religare Laboratories Pharmaceutical, healthcare and biotech 50
KKR TVS Logistics Services Logistics 48
Top PE deals: Q2 2012
second half of the year onwards, the former being
driven by attractive asset valuations, and thelatter by potential government measures to ease
FDI. The retail sector could also see heightened
activity once clarity is achieved on FDI in multi
brand retail.
The above deal rationales demonstrate that
whilst cross border activity might have slowed
down significantly, Indias fundamental growth
story remains strong. Ironing out governance and
structural issues could give the dealscape a much
needed shot in the arm.
Private Equity: Signs of a cautious slowdown
Private Equity (PE) for Q2 2012 fell by 38% to
total USD 1.8 billion, as compared to USD
2.9 billion for Q2 2011. The total deal values for
Q2 2012 have also registered a fall as compared
to Q1 2012, which saw USD 2 billion worth
of deals. While it may be too early to draw a
conclusive trend for PE for 2012, it seems that
PE investments have temporarily slowed down,
most likely due to the economic and regulatory
uncertainties currently clouding India.
Top sectors for PE in the quarter included IT& ITES (18%), pharma, healthcare and biotech
(15%), power and energy (14%), BFSI (13%)
and hospitality (8%). However, PE investors
who look at long term returns, have also
invested in those sectors of the Indian economy
that currently have a huge demand and supply
mismatch (power and energy), and massive
potential due to a burgeoning middle class with
rising disposable incomes (hospitality).
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Karthik Balisagar
Valuations Manager and AssistantHead of Valuations South Asia Group
Grant Thornton UK LLP
T+44 (0)20 7865 2475
With special
thanks for their
contribution to
Ankita Arora
and Sowmya
Ravikumar of the
Grant Thornton
India Dealtracker
team.
IT & ITeS [18%]
Pharmaceuticals,healthcare and biotech [15%]
Power and energy [14%]
Banking and financialservices [13%]
Hospitality [8%]
Others [31%]
Top PE sectors: April - June 2012Outlook for H2 2012
Notwithstanding the rather dismal M&A, andlackluster PE performance for Q2 2012 quarter,
this could well be the proverbial darkest hour
before the dawn.
The end of June 2012 saw some welcome and
rapid reprieves clarifications on GAAR not
being applied on a retrospective basis, an arrest
of the free-fall of the rupee and the resumption
of responsibility for the finance ministry by
the Prime Minister Manmohan Singh, who was
instrumental in Indias economic liberalisation in
1990. From a valuation perspective, analysts now
deem India to be trading at historically low levels,and hence see attractive multiples. Further, Indias
domestic demand remains strong, thanks to rising
consumption levels and increasing purchasing
power in 2011, India rose to third place globally
in terms of purchasing power parity, only
behind USA and China, with reports suggesting
that India will continue to be the third largest
economy in 2015. The combination of these
factors could be a renewed interest in
Indian entities by foreign players and higher
inbound activity.Key drivers of outbound M&A such as strong
balance sheets, the need to look beyond home
markets and attractive valuations continue to
exist, even if the current economic uncertainty
in the European and American markets may
have put the cross border ambitions of Indian
companies temporarily on hold. Factors such as
the recent unveiling of a plan to address
Europes distressed banking sector by European
leaders could, if successful, see a rebound in
outbound M&A.
Finally, if the momentum demonstrated so far
by domestic deal activity also sustains in H2 2012,
the dealscape may see a turnaround in the latter
half of 2012. However, the industry will also
keep a wary eye on headwinds such as a possible
increase in fuel prices, deterioration of the
European situation, lackluster demand for exports
from other nations such as US, and much closer
home poor monsoons.
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Munesh KhannaSenior Partner
Grant Thornton India LLP
T+ 91 22 6626 2600
In the first three months of 2012 Indiaseconomy grew at its slowest rate since 2003with GDP growth of only 5.3% in comparisonto the same period in 2011 well below analystexpectations and a decline of around 80 basispoints from the previous quarter (October 2011
to December 2011).The wider view of Indias economic position
also shows a substantial decline in economicgrowth. For the financial year to March 2012,Indias real GDP fell to around 6.5%, down from8.4% in the previous financial year.
So what has been the cause of this decline?
Persistently high inflation has dogged Indiaseconomy for a number of years now and evenwith a near-monthly increase in the countryskey interest rate recently (although it was kept at
8% in the last meeting of Indias central bank),inflation continues to be a significant thorn inthe side of Indias economy and its quest forstabilisation and increased growth.
The value of the rupee against the dollar hasalso played a material part in the destabilisationof Indias economy over the last few months inparticular. As reported by the BBC, since July lastyear, the Indian rupee has seen one of the biggestdeclines among Asian currencies against the dollar dropping by more than 27%. The depreciationof the rupee, coupled with a backdrop ofdeclining global demand and high inflation (as
highlighted above) has made the creation of aplatform from which sustainable and increasingeconomic growth can be achieved, incrediblychallenging.
While Indias government has attempted tointroduce new policies to help battle the countryseconomic decline, many analysts feel there is amajor lack of impetus as well as a clear, realisticgrowth plan. In addition, some important neweconomic reforms (particularly those which willallow greater foreign investment in India) havebeen delayed, for over a year, amid the on-going
corruption scandals which continue to cast a darkshadow over Indias political arena and furtherincrease the risk profile of the country for manyof those international institutions interested ininvesting in Asias third largest economy. The
An update on the Indian economyIn this economic update we take a look back over the last six months and reviewwhat progress and developments have taken place in Indias economy.
likely consequences of these corruption scandalsbeing that many prospective investors will eitherfeel that Indias risk profile is now too high forsignificant capital deployment or that valuationswill need to be knocked back considerably toaccount for the increased risk.
On a positive note however, and as reported inthe Economist:
IKEA, a Swedish furniture chain, boostedmorale by saying it would invest up to1.5 billion ($1.9 billion) in Indiaalthoughon closer inspection that sum was spread overmany years. Coca-Cola followed suit with theannouncement of an additional $3 billion ininvestment, taking the total earmarked for Indiaby 2020 to $5 billion. A ratings agency provedoddly helpful, too: on June 25th Moodys signalledit would not follow Standard & Poors and Fitch,
which have both warned of a possible downgradeof India to junk status. Its rating, which hoversjust within investment grade, remains stable, theagency said.
In addition, there is further hope following therecent resumption of responsibility for the financeministry by the Prime Minister, ManmohanSingh. Pranab Mukherjee, the previous financeminister, left his position on 26 June following aterrible time in office overseeing a substantialdecline in Indias growth rate, spiralling inflationrates and failing to put in place a suitable solutionfor Indias budget deficit. The hope in Premier
Singh comes from his previous track record asfinance minister, a position he held in 1991, whenhe was the driving force behind the opening upof India economy to foreign investment and theinitiation of the privatisation of publicsector companies.
The extent to which the appointment ofPremier Singh as finance minister will helpreverse the countrys current economic prospectswill be seen in time but it will certainly be seenas a move forward for many within India andthe wider global economy. If Premier Singh
is able to implement the much needed policyreforms prior to the next general election in 2014,Indias economy outlook is likely to improveconsiderably.
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Adam ForsythResearch Director
Arden Partners
T+44 (0) 20 7614 5952
Indian power the next five yearsDespite threats to Indias GDP growth, powerdemand in India remains resilient. Against this,a significant barrier to entry has arisen: accessto coal. This will slow supply of new capacity,maintain a power deficit and put upward pressureon prices, despite the threat of lower growth.
Companies that have secured access to coal, orthose that are not dependant on it, are now in astrong position to benefit from better pricing andcontinued growth opportunities for new projects.
Power shortages remain a problem acrossIndia. Despite adding a record amount of newcapacity in 2011/12, the gap between peakpower demand and available capacity increasedfrom 9.8% to 10.6%. Recent press reports havehighlighted significant power cuts with someareas of Uttar Pradesh, Uttarakhand and AndhraPradesh facing outages of between four and nine
hours a day.In order to address this problem, India isplanning to add almost 100GW of new powercapacity over the next five years to an installedbase of 200GW. If successful it will be addingmore than the total installed capacity in the UK.However, almost 60% of the new capacity istargeted to come from coal generation and coalsupplies have come under pressure.
While there is political will to improve coalsupplies, we think there will still be a coal deficitacross the next five years. Coal India Limited willimprove production but the significant planned
increase in capacity means that the power sectorwill still need more imported coal. Imports ofcoal to the power sector could potentially doubleto meet the demands of new capacity.
A problem then arises because Indian powerstations have been designed for low calorie, highash Indian coal and are limited in the amount ofhigher calorie imported coal that they can burn.While new stations will be more flexible, policyis that, with the exception of specific coastalstations, they retain the ability to burn all Indiancoal if required. This factor will limit the total
amount of new capacity that can be added.As a result, even if we factor in a lower GDP
growth rate of just 6%, a power deficit is likely toremain despite the corresponding lower growthin peak demand. This means that there will still
be opportunities for new capacity developers whocan secure coal or who do not need it.
It is also likely that more imported coal willput upward pressure on electricity prices. Evendespite the recent fall in global coal prices, theyremain some 36% above the price of Indian coal
after adjusting for differences in calorific valueand transportation. The use of more importedcoal in the Indian fuel mix will raise the averagecost of production. Additionally some of thelarger power producers bid for contracts on thebasis of very low cost Indonesian coal. Indonesiahas subsequently introduced legislation tolink the price of exported coal to internationalbenchmarks, damaging the economics of thesecontracts. There is now considerable pressurefrom the power companies to have contractsrevised upwards.
The pressure for price increases may betempered by weaker global coal prices althoughthey would have to fall a lot further. Upwardrevisions may also be limited by the abilityof the State Electricity Boards (SEBs) to payfor increases. However, with 16 SEBs in theprocess of implementing end-user tariff increasesthemselves, there is scope for the prices paid togenerators to improve in the long run.
In summary, the continuing deficit meansopportunities to bring new capacity to the marketwill remain and the upward pressure on pricesmeans that the potential rewards for doing so
should improve. Of course any new capacity willeither need secured coal supplies or not dependon coal. As a result we see opportunities forcompanies with secured coal (either in India orabroad) and for companies developing
renewable capacity.
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Some of the emerging concerns, mentioned
below, are dampening M&A activity and thefunding market.
1 Very wide scope: Scope of Indian GAAR
is very wide as it seeks to cover all the
arrangements which have an element of tax
benefit accruing to the taxpayer.
2 GAAR v treaty provisions: Proposed GAAR
provisions would apply even if the treaty
provisions are more beneficial. A unilateral
enactment of a new domestic tax law which
is contrary to an existing treaty, without an
amendment to that treaty, could possibly beregarded as violation of international law and is
generally known as treaty override.
As per the rules of legislative interpretation,
specific legislation overrides general legislation.
Therefore, the argument may be taken that
a change to a domestic law generally, which
could be the case with GAAR, may not affect
the treaty. However, in the absence of an anti-
avoidance provision under the treaty, reaction
of Indias treaty partner countries needs to
be observed.
3 Wide powers of tax authorities: Tax authorities
are given powers to invoke GAAR by using
any one of the criterion which are vast as
well as ambiguous. Thus there is a need to
lay down more objective criteria and specific
administrative guidelines for invoking
GAAR and to establish a reasonable level of
accountability for the tax authorities.
4 Constitution of the Panel:It may be ideal if
certain industry experts are nominated for
the Approving Panel who can bring in their
expert knowledge/experience which can helpunderstanding the true business or commercial
purpose of a transaction.
Conclusion
A countrys tax regime is a very significant factorif not decisive factor for a foreign investor to invest
its funds in any jurisdiction. Today businesses
are looking at inorganic growth to achieve better
economies of scale, synergy and competency in the
form of business reorganisations. Therefore the
tax policies of the government need to be critically
framed as to achieve the purpose of tax reform and
also to be positive to the business environment of
the country.
Worldwide, GAAR has been criticised and
supported equally by international tax experts.The rule of law requires law to be certain and
predictable, such that law abiding citizens are
aware of what is permitted and what is prohibited.
While the concept of GAAR may be against this
principle, to some extent, GAAR is important,
since it is not humanly possible to make laws
for each and every tax avoidance tool used by a
creative taxpayer.
The success of GAAR lies in its judicious,
selective and sensible implementation. In the
Indian context, considering the aggression of tax
administration in some cases, the introduction of
GAAR may be worrisome to a tax payer unless
implemented in a balanced manner with adequate
safeguards for protecting the taxpayer. Tax payers
would keenly await draft subordinate legislation,
which law makers expect would be open for
public debate.
The intent of the Indian lawmakers to legislate
GAAR is progressive in so far as tax policy
decisions are directed. However, an important
question is whether, in the current context, the
introduction of GAAR is well timed, or if it isstill a premature effort towards alignment with
internationally accepted principles of
anti-avoidance.
Anshu Khanna
Partner Tax & RegulatoryPractice
Walker, Chandiok & Co
T +91 40 6630 8240
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