Financial Services. Financial Services

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1 Financial Services Financial Services Tax Alerts cover significant tax news, developments and changes in legislation that affect Indian businesses. They act as technical summaries Tax alerts to cover keep you significant on top of tax the news, latest tax developments issues. For more information, and changes please in legislation contact your that EY affect advisor. the Indian businesses. They act as technical summaries to keep you on top of the latest tax issues. For more information, please contact your EY advisor.

2 Introduction This alert summarizes certain significant tax proposals contained in the Finance Bill, 2015 (Bill) and policy announcements made by the Finance Minister (FM), Mr Arun Jaitley, during the Budget speech relevant to the financial services sector. The policy pronouncements made by the FM are expected to be implemented by the Government through legislative/ administrative announcements (where required) 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. amendment to this effect has been proposed in the Foreign Exchange Management Act, A task force to be created to establish a sector neutral Financial Redressal Agency that will address grievances against all financial service providers. Banks and Non-Banking Financial Companies (NBFCs) The RBI Act, 1934 will be amended to provide for a Monetary Policy Committee. The direct tax proposals discussed in this memorandum are effective from the financial year commencing on 1 April 2015, unless otherwise specified. Key Policy Initiatives Some of the key initiatives announced by the FM in his budget speech are summarised as under: Financial sector and capital markets Issuance of tax free infrastructure bonds for projects in railway, roadway and irrigation sector. Comprehensive Bankruptcy Code to be introduced which will meet global standards and provide necessary judicial capacity. The Indian Financial Code to be shortly introduced in the Parliament for consideration. Autonomous bank board bureau to be set-up to improve governance of public sector banks. The bureau will select heads of public sector banks and help them in developing differentiated strategies and capital raising plans through innovative financial methods and instruments. Deepening the Indian bond market by setting-up a Public Debt Management Agency to bring India s external borrowings and domestic debt under one roof. Merger of the Forward Markets Commission with the Securities and Exchange Board of India (SEBI) to strengthen regulation of commodity forward markets and reduce speculation. The Government in consultation with the Reserve Bank of India (RBI) shall keep a control on capital flows as equity. An NBFCs registered with RBI and having asset size of INR 5 billion and above to be considered for notification as Financial Institution in terms of the Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (SARFAESI). Investment Foreign investment permitted in Alternative Investment Funds (AIF).

3 Distinction between different types of foreign investments, especially between foreign portfolio investments and foreign direct investment, to be done away with and replaced with composite caps. Tax reforms taxpayers. However, the FM, in his budget speech, indicated that the corporate tax rate for domestic companies is proposed to be reduced from 30% to 25% over the next four years accompanied by rationalisation of tax exemptions and incentives. Surcharge and education cess Direct Taxes Code proposed to be dropped. Various measures proposed to curb black money. Implementation of recommendations of the Tax Administration reform Commission. Other reforms The Bill proposes to increase the surcharge levied on domestic companies from 5% to 7% where the total income exceeds INR 10 million but not INR 100 million, resulting in an effective tax rate of %. Where the total income exceeds INR 100 million, it is proposed to increase the surcharge from 10% to 12% resulting in an effective tax rate of %. National Investment and infrastructure Fund to be established to provide an impetus to the infrastructure sector. The rate of surcharge applicable to foreign companies has remained unchanged. An Expert Committee to be appointed for preparing a draft legislation to replace multiple prior permissions with a pre-existing regulatory mechanism. Sovereign Gold Bond and Gold Monetisation Scheme to be introduced for monetising Gold. Appropriate regulations to be issued in March for Gujarat International Finance Tec-City (which has been envisaged as an International Finance Centre). For non-corporate taxpayers, the surcharge is proposed to be increased from 10% to 12% 1. Education cess will continue to be levied at the prevailing rate of 3% on the amount of tax computed inclusive of surcharge, in all cases. Other tax rates Consequent to the proposed increase in surcharge, certain effective tax rates 2 are as follows: Direct Taxes Tax rates Basic tax rates Minimum Alternate Tax (MAT) for domestic companies % (where the total income exceeds INR 10 million but not INR 100 million)/ % (where the total income exceeds INR 100 million). The basic tax rates applicable to corporate and non-corporate taxpayers remain unchanged for both domestic and foreign 1 Surcharge is currently leviable on non-corporate tax payers having total income exceeding INR 10 million during the relevant financial year. 2 These rates do not reflect the impact of the grossing-up of income/ dividend distribution introduced by the Finance (No 2) Act, 2014.

4 Dividend Distribution Tax (DDT) on domestic companies %. Tax on buyback of shares by unlisted domestic companies %. Income distribution tax on mutual funds other than equity oriented mutual funds % on income distributed to Individuals/ Hindu Undivided Families and % on income distributed to others. Income distributed by an infrastructure debt scheme to non-residents %. Royalty and fees for technical services (FTS) The Bill proposes to reduce the withholding tax rate on royalty and FTS paid to non-residents from the current rate of 25% to 10%. Deferral of applicability of General Anti-Avoidance Rule (GAAR) GAAR was introduced by the Finance Act, 2012 to be effective from the financial year with the objective of dealing with aggressive tax planning through the use of sophisticated structures and codifying the doctrine of substance over form. The provisions of GAAR are to be applied in accordance with guidelines which have been issued in the form of prescribed rules (GAAR Rules). The GAAR Rules, inter alia, provide that GAAR shall not apply with respect to income arising from transfer of investments made prior to 30 August The Bill now proposes to make the provisions of GAAR applicable prospectively with effect from the financial year Further, the FM, in his budget speech has indicated that GAAR would apply prospectively to investments made on or after 1 April This would require amendments to the Income-tax Rules, Clarification pertaining to indirect transfer provisions Currently, income arising from, inter alia, any asset or source of income in India or through the transfer of a capital asset situated in India is deemed to accrue or arise in India. In this regard, the Finance Act, 2012 provided that an asset or a capital asset being any share or interest in a company or entity registered or incorporated outside India shall be deemed to be situated in India, if the share or interest derives, directly or indirectly, its value substantially from assets located in India. Based on the recommendations provided by an Expert Committee constituted by the Government, the Bill proposes the following amendments relating to indirect transfer provisions: The share or interest shall be deemed to derive its value substantially from assets (tangible or intangible) located in india, if on a specified date 3, the Based on the recommendations of an Expert Committee constituted by the Government, the applicability of GAAR was deferred by the Finance Act, 2013 to the financial year Specified date shall mean i. date on which the accounting period (i.e. period of 12 months) of the company or entity ends, preceding the date of transfer; or ii. date of transfer, if the book value of the assets of the company or entity on the date of transfer exceeds the book value of the assets as on the date referred to in (i) above, by 15%.

5 value of Indian assets 4 : Exceeds INR 100 million; and Represents at least 50% of the value of all the assets owned by the company or entity. Income shall not accrue or arise to a non-resident in case of transfer of any share or interest in a foreign entity which directly owns the assets situated in India (direct holding company), if the non-resident along with its associated enterprises at any time in 12 months preceding the date of transfer: neither holds the right of management or control in the direct holding company; nor holds voting power/ share capital/ interest exceeding 5% of the total voting power/ total share capital/ total interest of the direct holding company. Income shall not accrue or arise to a non-resident in case of transfer of any share or interest in a foreign entity which indirectly owns the assets situated in India (indirect holding company), if the non-resident along with its associated enterprises at any time in 12 months preceding the date of transfer: neither holds the right of management or control in the indirect holding company; nor holds voting power/ share capital/ interest in the indirect holding company which would entitle it to exercise control or management in the direct holding company or entitle it to 4 Value of the asset shall mean its fair market value, to be determined in a prescribed manner, without reduction of liabilities in respect thereof. voting power/ share capital/ interest in the direct holding company exceeding 5% of the total voting power/ total share capital/ total interest of the direct holding company. The taxation of gains arising on transfer of a share or interest deriving, directly or indirectly, its value substantially from assets located in India will be on proportional basis and shall be computed in a prescribed manner. Additionally, the Bill proposes that the following transfers of a capital asset (subject to certain conditions) shall not be regarded as transfer for the purpose of charging capital gains tax: In a scheme of amalgamation, transfer of a capital asset, being a share of a foreign company which derives, directly or indirectly, its value substantially from the shares of an Indian company, held by the amalgamating foreign company to the amalgamated foreign company. In a scheme of demerger, transfer of a capital asset, being a share of a foreign company which derives, directly or indirectly, its value substantially from the shares of an Indian company, held by the demerged foreign company to the resulting foreign company. Further, the Bill proposes that the Indian concern through or in which the Indian assets are held by the foreign company or entity shall be required to furnish information relating to indirect transfer of a share or interest in a company or an entity incorporated outside India, in a prescribed manner. Penalty is proposed to be levied on

6 the Indian concern on failure to comply with the reporting requirements as follows: 2% of the value of the transaction, where such transaction had the effect of, directly or indirectly, transferring the right of management or control in relation to the Indian concern; or INR 0.5 million in any other case. Residential status of companies i.e. Category I AIF (this in turn has few sub-categories), Category II AIF and Category III AIF. Currently, the domestic tax law provides for a pass through status for income earned by, inter alia, a Category I AIF venture capital fund (VCF) sub-category registered with the SEBI. In order to rationalise the taxation of Category I AIF and Category II AIF (together referred to as 'investment fund ), the Bill proposes to provide a special tax regime, the key features of which are as under: Presently, a company is considered to be resident in India for a financial year if: It is an Indian company; or During the financial year, the control and management of its affairs is situated wholly in India. The Bill proposes to amend the criteria for determining the residential status of a company by incorporating the concept of place of effective management (POEM) in the domestic tax laws. Thus, in line with international standards and the provisions of Double Taxation Avoidance Agreements (DTAAs), the Bill proposes that a company shall be a resident in India for a financial year if: It is an Indian company; or Its POEM, at any time in the year under consideration, is in India. The term POEM is proposed to mean a place where key management and commercial decisions necessary for the conduct of business of an entity, as a whole are, in substance made. Taxation of AIFs As per the SEBI (AIF) Regulations, 2012, AIFs are classified under three categories Income of a unit holder of an investment fund shall be chargeable to tax in the same manner as if it were income from investment made directly by the unit holder; Income in the hands of the unit holder shall be of the same nature and in the same proportion as if it were income arising to the investment fund; Income (other than business income taxable at the fund level) shall be exempt from tax in the hands of the investment fund and taxable in the hands of the unit holder; Profits and gains of business or profession shall be taxable in the hands of the investment fund and consequently, be exempt in the unit holder s hands; Taxes shall be withheld at the rate of 10% with effect from 1 June 2015 on income payable by an investment fund to a unit holder (other than on income that is taxable at the fund level i.e. as business income); Net loss at the fund level shall not be allowed to be passed through to the unit holders but would be carried over at the fund level to be set-off against income of subsequent years in accordance with the applicable provisions of the domestic tax law;

7 DDT or tax on distributed income shall not apply to the income paid by an investment fund to its unit holders; Income to be received by the investment fund would not be subject to tax withholding requirement 5 ; The investment fund shall be required to file a return of income, and provide to the Indian Revenue authorities and unit holders, the details of various components of income and such other particulars as may be prescribed; and The VCFs /companies registered under the SEBI (VCF) Regulations, 1996 shall continue to be governed by the existing provisions of the domestic tax law. No business connection for fund managers in India Presently, the domestic tax law provides that income shall be deemed to accrue or arise in India, inter alia, through or from any business connection in India. In the case of an offshore fund, the presence of a fund manager in India may create sufficient nexus of the offshore fund with India and hence, may constitute a business connection in India. Consequently, profits from investments of the offshore fund, whether made in India or outside India, may be liable to tax in India due to location of the fund manager in India. Additionally, presence of the fund manager in India under certain circumstances may lead to the offshore fund being held to be resident in India on the basis of its control and management being in India. In order to facilitate location of a fund manager of offshore funds to India, the Bill proposes that fund management activity of an eligible fund manager would not 5 As provided in the Memorandum to the Bill. constitute a business connection for an eligible investment fund in India. The Bill also provides that an eligible investment fund should not be said to be resident in India merely because the eligible fund manager, situated in India, undertakes fund management activities on its behalf. To qualify as an eligible investment fund, the following key conditions have been proposed by the Bill: The fund should not be a person resident in India and should be a resident of a country with whom India has entered into a DTAA; Participation/ investment by person resident in India (directly or indirectly) in the fund should not exceed 5% of the corpus of the fund; There should be minimum 25 members, who, directly or indirectly, are not connected persons; No member of the fund along with connected persons should have participation interest, directly or indirectly, of more than 10% in the fund; Aggregate participation interest of 10 or less members (directly or indirectly) along with their connected persons in the fund should be less than 50%; Investment by the fund in an entity should not exceed 20% of the corpus of the fund; The fund shall not make investment in an associate entity; Monthly average of the corpus of the fund should not be less than INR 1 billion; The fund shall not carry on or control and manage (directly or indirectly) any business in India or from India; and The remuneration paid by the fund to an eligible fund manager in respect of

8 any fund management activity should not be less than the arm s length price. To qualify as an eligible fund manager, the following key conditions have been proposed by the Bill: The person should not be an employee of the eligible investment fund or a connected person of the fund; The person should be registered as a fund manager or investment advisor in accordance with specified regulations and should act in the ordinary course of his business as a fund manager; The person along with its connected persons should not be entitled to more than 20% of the profits accruing or arising to the eligible investment fund from the transactions carried out by the fund through such fund manager. Further, the Bill provides that an eligible investment fund shall furnish a statement containing information in connection with fulfilment of conditions in a prescribed manner failing which a penalty of INR 0.5 million shall be levied on the fund. income from self under the domestic tax law. With a view to providing clarity and certainty, the Bill proposes that the Indian branch [being a permanent establishment (PE) of the HO in India] shall be deemed to be a separate and independent person from the HO of which it is a PE. Accordingly, the interest payable by the Indian branch to its HO or to any other overseas branch of the foreign bank, shall be deemed to accrue or arise in India and shall be chargeable to tax in India in addition to any income attributable to the Indian branch. Consequently, the Indian branch shall be obligated to withhold tax on such interest payable to the HO or to any other overseas branch of the HO. Extension of eligible period of concessional tax rate on interest earned by Foreign Institutional Investors (FIIs) 6 on specified investments Taxation of interest received by a head office/ overseas branch of a banking entity from its Indian branch Historically, the deductibility of interest paid by an Indian branch of a foreign bank (Indian branch) and the corresponding taxability of such interest in the hands the head office (HO) of the foreign bank has been a subject matter of litigation. Certain judicial precedents have held that interest paid by an Indian branch to its HO is deductible in the hands of the Indian branch based on the DTAA provisions and the said interest is not taxable in the hands of the HO on the basis that the said receipt qualifies as Currently, interest payable to a FII during the period 1 June 2013 to 31 May 2015, on rupee denominated bonds of an Indian company or a Government security is taxable at a lower rate of 5% (plus applicable surcharge and education cess), provided the rate of interest (with respect to rupee denominated bonds of an Indian company) does not exceed the rate notified by the Central Government. The Bill proposes to extend the benefit of the concessional tax rate in respect of interest payable on the aforesaid securities upto 30 June As notified by the Central Board of Direct Taxes, FIIs include Foreign Portfolio Investors.

9 Rationalizing the MAT provisions for FIIs Currently, a company is liable to pay MAT at the rate of 18.5% (plus applicable surcharge and education cess) on its book profits, if the same is higher than the tax calculated under the normal computational provisions. For the purposes of calculating the book profits, a company is required to prepare its Profit and Loss Account in a prescribed manner. Further, certain specific additions and deductions are required to be made to the book profit as specified under the MAT provisions. The Bill proposes to, inter alia, exclude capital gains [other than short-term capital gains not subject to levy of securities transaction tax (STT) 7 ] earned by FIIs on sale of Indian securities and corresponding expenditure, if any, to be added back in computing the book profit for MAT purposes. Conceptually, the applicability of MAT to FIIs which do not have a presence in India, an issue which is pending adjudication by the Supreme Court of India has not been addressed. Similarly, the interplay of MAT provisions with the provisions of a DTAA to a corporate entity has not been dealt with by the amendments. Taxability of income from Global Depository Receipts (GDR) The Depository Receipts Scheme, 2014 notified by the Department of Economic Affairs vide notification dated 21 October 2014 (new scheme) has replaced the Issue of Foreign Currency Convertible Bonds and Ordinary Shares 7 This exclusion is immaterial as such gains are taxable at a rate higher than the MAT rate. (through depository receipt mechanism) Scheme, 1993 (erstwhile scheme). Presently, the taxation scheme of income arising from GDRs under the domestic tax law deals with the erstwhile scheme which was limited to issue of GDRs based on the underlying shares of the company and where the company was either listed or was to list simultaneously. The new scheme provides that GDRs can be issued against securities of listed/ unlisted/ private/ public companies and against underlying securities which can be debt instruments, shares, units, etc. Further, GDRs are permitted to be held and transferred by both residents and non-residents. To restrict the availability of tax benefits under the domestic tax law to GDRs issued against shares of listed companies, the Bill proposes to amend the definition of the term GDR to mean GDR issued to investors (both resident and non-resident) against ordinary shares of a company listed in India. The taxation of GDRs issued in other cases (i.e. unlisted companies, GDRs issued against underlying securities not being ordinary shares) has not been dealt with by the Bill, hence, the same would need to be determined based on the legal structure, facts and circumstances of individual issuances. Tax neutrality on consolidation of similar schemes of mutual funds SEBI has been encouraging mutual funds to consolidate different schemes having similar features with a view to have simple and fewer number of schemes. However, such consolidation presently results in capital gains tax payable by unit holders. In order to facilitate consolidation of mutual fund schemes in the interest of investors, the Bill proposes to exempt the transfer of

10 units in the hands of unit holders upon consolidation of schemes, provided they are allotted units in the consolidated scheme of the mutual fund. The aforesaid exemption is proposed to be provided only where the consolidation is of two or more schemes of an equity oriented mutual fund or of two or more schemes of a non-equity oriented mutual fund. Further, it is proposed that the cost of acquisition and the period of holding of units held by unit holders in the consolidated scheme shall, respectively, be the cost of acquisition and the period of holding in the consolidating scheme. Taxation of Real Estate Investment Trust (REITs) and Infrastructure Investment Trust (IITs) Currently, REITS and IITs are granted a pass through status, in respect of interest income earned from Special Purpose Vehicles (SPVs) 8. Such interest income from SPVs is taxable in the hands of the investors and accordingly, REITs and IITs are required to withhold tax at specified rates (10% for residents and 5% for non-residents). Further, any capital gains arising to the REITs and IITs on disposal of their assets are taxable in the hands of the REITs and IITs at the applicable rates and the component of distributed income attributable to such capital gains are exempt in the hands of the investors. Any other income earned by the REITs and IITs is taxable at the maximum marginal rate and distributions made therefrom by REITs and IITs are exempt from tax in the hands of the investors. The Bill proposes to extend the pass through status to rental income earned by a REIT from real estate property directly held by it. Accordingly, it is proposed that such rental income would be received by the REIT without suffering withholding tax. However, the rental income distributed by the REIT would be taxable in the hands of the investors and the REIT would be required to withhold tax at specified rates (i.e. 10% for residents; 40% for foreign companies and 30% for other non-residents, subject to relief under a DTAA). Presently, capital gains arising on sale of units of REITs and IITs listed on a recognised stock exchange in India are taxable at the beneficial rate applicable to capital gains arising on sale of equity shares of a company listed on a recognised stock exchange in India (i.e. short-term capital gains taxable at 15% and exemption for long-term capital gains). However, capital gains arising to the sponsor of REITs/ IITs on transfer of shares of a SPV to REITs/ IITs in exchange of units is not eligible for such beneficial treatment and is taxable in the year in which such units are transferred. The deferral of capital gains provided to the sponsor of REIT/ IIT places the sponsor at a disadvantageous tax position vis-a vis direct listing of the shares of the SPV. In case the sponsor holding the shares of the SPV decides to exit through the Initial Public Offer route, then the benefit of concessional tax regime relating to capital gains arising on transfer of shares, subject to levy of STT, is available. Thus, in order to provide parity, the Bill proposes that the sponsor should get the same concessional tax treatment (i.e. short term capital gains taxable at 15% and exemption for long-term capital gains) on transfer of units of the REIT/ IIT under an IPO on listing of units, subject to levy of STT at the rate of 0.2% on the price at which such units are sold. 8 SPV is defined as an Indian company in which the IIT or REIT holds controlling interest and any specific percentage of shareholding or interest, as may be required by the regulations under which such trust is granted registration.

11 Increase in the threshold for specified domestic transactions (SDT) Presently, the term SDT has been defined to mean any specified transaction, not being an international transaction, where the aggregate of such transactions entered into during a financial year exceeds a sum of INR 50 million. Service tax The changes in the rate of service tax to apply from a date to be notified once the Bill is enacted are as follows: Effective service tax rate increased from 12.36% to 14%. Education cess and secondary higher education cess subsumed in the service tax rate. With a view to address the issue of compliance cost in case of small businesses, the Bill proposes to provide that the aggregate limit of specified transactions entered into during a financial year should exceed INR 200 million to be treated as SDT. Incremental Swachh Bharat Cess of 2% to be applicable on services to be notified (resulting in an effective rate of 16%). Corresponding increase in the composition rates for the following key services: Wealth tax Currently, wealth-tax is levied on, inter alia, a company, at the rate of 1% of the amount by which its net wealth exceeds INR 3 million. The Bill proposes to abolish the levy of wealth-tax under the Wealth-tax Act, 1957 with effect from the financial year Indirect Taxes Goods & Service tax (GST) The FM has re-emphasized the intent of the Government to introduce GST by 1 April GST is aimed at playing a transformative role in developing a common Indian market and reducing a cascading effect. Particulars Life insurance services Services of buying and selling of foreign exchange, including money changing Composite service tax rates 3.5% of premium in first year and 1.75% of premium in subsequent years Gross 0.14% of money the gross exchanged - money up to exchanged INR 0.1 subject to million maximum of Gross money exchanged - from INR 0.1 million up to INR 1 million Gross money exchanged - above INR 1 million INR 35 INR 140 plus 0.07% of the gross money exchanged INR 770 plus 0.014% of the gross money exchanged up to maximum of INR 7,000

12 Key amendments to non-taxable/ exempted services Exemption on services by mutual fund agent/ distributor withdrawn, service taxable in the hands of mutual fund/ asset management company under reverse charge provisions - applicable with effect from 1 April Life insurance by way of Varishtha Pension Bima Yojna exempted from service tax - applicable with effect from 1 April All services provided by the Government to business entities (unless specifically included in Negative List) to be taxable date of applicability to be notified. Clarity on taxability of services provided by a chit fund foremen by way of conducting a chit applicable on enactment of the Bill (resulting in an effective rate 16%). Tax controversies Advance Ruling provisions extended to resident firms, effective immediately. Immunity to penalty for reasonable cause withdrawn applicable on enactment of the Bill. Particulars Nonevasion cases Penalty Up to 10% of service Service tax, interest paid within 30 days of notice Service tax, interest and reduced penalty paid within 30 days of order Other key changes Evasion cases 100% of service tax tax No penalty 15%, provided such reduced penalty is also paid 25% of penalty, provided such reduced penalty is also paid 25%, provided such reduced penalty is also paid Clarification that agency services provided by banks to RBI are taxable. Full reverse charge applicable with effect from 1 April 2015 for following services provided by an individual, HUF, or partnership firm: Manpower supply services; Security services. Procedural relaxations introduced with effect from 1 March 2015: Rebate matters for export of services or goods to be appealed before Revisionary Authority, present matters before Tribunal to be transferred applicable from enactment of the Bill. Rationalisation of penal provisions - applicable on enactment of the Bill: Speedy registration within 2 days for single premise application. Option to maintain digitally signed invoices and electronic records introduced. Aggregator made liable to tax on services provided by any person using brand name/ trade name of such aggregator. Cenvat Credit Timeline to avail Cenvat credit on inputs and input services extended to 12 months from the date of the invoice/ other relevant document effective 1 April 2015.

13 Cenvat credit in relation to partial reverse charge, available at the time of payment of service tax effective 1 April Wrong availment of Cenvat credit to attract recovery proceedings effective 1 March Customs Effective median rate increased from 28.85% to 29.44%. Excise Effective median rate increased from 28.85% to 29.44%.Median rate increased from 12.36% to 12.5%. Comments The Union Budget contains a slew of measures targeted at the financial services sector. Clarifications in the law for fund management of offshore funds in India should provide an impetus to partially reverse the export of the fund management industry overseas. Deferral of GAAR and clarity in indirect transfer rules are a welcome relief. Pass through status to AIFs and SARFAESI to NBFCs should provide a fillip to these sectors. On the balance, while calibrations may be required for some proposals to be fully effective, the budget has provided an impetus to several financial services sub-sectors. Useful links :EY Tax and Regulatory Services I EY Tax webcast series I Direct Taxes Code I EY Tax Library I Doing Business in India I Working in India

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