MAT Impact For Ind AS Compliant Companies

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ACCOUNTANTS MAT Impact For Ind AS Compliant Companies Chartered accountants

INDEX Applicability of IND AS 1 2 Objective of MAT Provisions for Ind AS Compliant Companies Impact of MAT under IND AS Framework 3 4 5 6 7 Methodology for MAT computation Summary of Adjustments under MAT Practical Illustrations on MAT Provisions FAQ issued by CBDT on certain Items

Applicability of IND AS NW Rs. 500 cr Companies listed or in process of listing (India/abroad) Companies listed or in process of listing (India/abroad) Unlisted Companies Applicable from Aprl NW Rs. 500 cr Unlisted Companies NW Rs. 250-500 cr Applicable from Aprl Note: 1) Indian Holding, Subsidiary, JV or AE of above (irrespective of NW) 2) 1st time adoption companies as on Mar17 & Mar 18, IND AS shall apply from FY 2017-18 & FY 2018-19

Applicability of IND AS NBFC (as defined u/s 45I(f) of RBI Act) w.e.f. April 2018 (FY 2018-19) Companies listed/in process whose NW Rs. cr Unlisted companies having NW Rs. cr w.e.f. April 2019 (FY 2019-20) Companies listed/in process whose NW Rs. cr Unlisted companies having NW Rs. 250-500 cr It Includes holding, Subsidiary, JV or AE of above companies

Objective of MAT Provisions for Ind AS Compliant Companies For FY 2016-17, Company will prepare Ind AS financial statements for the first time, as applicable. Comparative previous year 2015-16 under Ind AS will also need to be provided. Consequently Transition Date (TD) will be 01.04.2015 Considering different book profits for Ind AS compliant companies as compared to Indian GAAP, clarity on MAT provisions has been incorporated by Finance Act 2017 for such Ind AS compliant companies on first time adoption (FTA) and on an ongoing basis

Impact of MAT under IND AS Framework Routing of transitional Adjustments under IND AS Profit & Loss Ax/c Re-classifiable to P/L Other Comprehensive Income Total Comprehensive Income Non Re-classifiable to P/L Other Equity

Impact of MAT under IND AS Framework IND AS Framework in Convergence period FY 2016-17 (TD 01.04.15) Adoption Year Convergence Phase FY 2017-18 (TD 01.04.16) FY 2015-16 FY 2016-17 Reinstatement Year

Methodology for MAT computation Net Profit Before Tax as per Statement of P&L Add/Less Book profit to be used to compute MAT Effects of normal MAT provisions - Explanation 1 to Sec.115JB(2) A Add/Less Adjustments for any other OCI items that will not be re-classified to profit or loss B Add/Less Amount debited/credited to P/L on distribution of non-cash assets to shareholders in demerger as per IND AS 10 (Appendix A) C Add/less Adjustments for revaluation gain/loss for fixed assets & intangible assets in the year of their disposal or transfer. D Add/less Adjustments for gains or losses from investments in equity instruments measured at FVTOCI in the year if their disposal or transfer Book profit to be used to compute MAT

Methodology for MAT computation Book profit to be used to compute MAT Adjustments arising on account of transition to IND AS from existing Indian GAAP are required to be recorded under Other Equity in the balance sheet.-adjustment which will not be reclassified to Profit/loss shall be included in MAT computation equally over a period of 5 years-subject to following exceptions Add/less F Add/less Adjustments for revaluation gain/loss for fixed assets & intangible assets in the year of their disposal or transfer G Add/less Adjustments for gains or losses from investments in equity instruments measured at FVTOCI in the year if their disposal or transfer H Add/less Investment in JV, Subsidiary & Associates Measured at FV and adjustment in RE shall be included at the time of realisation I Add/less Any Adjusted made on account of cumulative translation difference relating to foreign operation shall be included at the time of disposal. J Total Book profit Computed as per Sec 115JB E

Summary of Adjustments under MAT Specified Adjustments - Illustrations Other Equity Accounted under OCI not re classifiable to P&L Revaluation of Property, Plant & Equipments & Intangible assets Gains/(losses) from investment in equity instruments designed at FVOCI Investments in subsidiaries, JVs and AE recorded at fair value as deemed cost as per Ind AS 101 Cumulative translation differences of foreign operations Point of Taxation - MAT On disposal/ realization/ retirement/ transfer

Specified Adjustments - Illustrations Point of Taxation - MAT OCI not re classifiable to P&L Remeasurements of defined benefit plans Gain on bargain purchase (BP) arising in a business combination subject to clear evidence for its underlying reason of such BP & gain is recognized in OCI Every year Year in which gain arises

Re-Classifiable Adjustment Illustrations Gains/Loss on Fair Value of FVOCI debt instruments Exchange differences on sale of foreign operations (foreign branches) i.e. Foreign Currency Translation Reserve Point of Taxation MAT (Reclassification to P&L as per Ind AS) disposal/ realization/ transfer Deferred gains/loss on cash flow hedges i.e. Cash flow hedge reserve Cumulative gains/(losses) arising when forecast transaction is no longer expected to occur Cumulative gains/(losses) arising on derecognition of financial assets Such items impacts P&L

Other TD Adjustment Othe E uity Components Point of Taxation - MAT Receivables are provided for based on Expected Credit Loss Fair value gains on derivative assets Equally over the period of 5 years Gains/(loss) on fair value recognition on Investment in MFs etc.

Practical Illustrations on MAT provisions Illustration 1: Bharat Electronics Ltd

Illustration 1: Bharat Electronics Ltd

Illustration 1: Case Study Year FY 15-16 Particulars IND AS (FV) 1,000 1,500 AS (Cost) Investment Value (Debt Component) Practical Illustrations on MAT provisions Sale Value Less: Asset Cost Bal. Transfer Other Equity Profit (P&L) Rs. 500 -> Other equity FY 16-17 AS (Cost) 1,000 IND AS (FV) FY 17-18 AS (Cost) IND AS (FV) 1,400 Rs. 100 -> OCI Re-classifiable to P&L 1,750 1,750 (1,000) (1,400) (0) 400 750 750 Conclusion : As per MAT, tax implication would be neutral

Illustration 2: Future Consumer Ltd

Illustration 2: Case Study Details of Debentures (CCDs) Issue Date 01.02.2012 Maturity Date 01.02.2022 Face Value of Debenture Rs.1000 No. of Debentures 40 Lakhs Valuation Date 01.02.2012 Rate of Interest 12% Rs. In Crores Debenture Value 400 Debt Component Equity Component 300 100

Rs. In Crores Illustration 2: Case Study Opening balance (Debt) Financial Year Effective Interest Rate Actual Interest Closing Balance Difference 2012-13 300 37 48 290 11 2013-14 290 35 48 270 13 2014-15 270 33 48 250 15 2015-16 250 30 48 225 18 Conclusion: As per MAT, amount transferred to RE of 39 & equity component of 100 will be taxable equally in 5 years RE - 39

Illustration 3: Welspun Corp Ltd

Illustration 3: Welspun Corp Ltd

Illustration 3: Case Study Particulars Transition Period Subsequent Year Year Finance Cost FY 2015-16 FY 2016-17 FY 2017-18 AS IND AS AS IND AS 1000 800 1000 900 Rs. 200 -> Other equity (MAT Tax) Rs. 100 -> OCI- Non classifiable (MAT Tax) AS IND AS 1000 Rs. (300) -> OCI- Non classified (MAT credit) Conclusion : As per MAT, tax implication would be neutral 1300

FAQs issued by CBDT on certain items Circular No. 24/2017 dated 25th July 2017 MTM gains/loss on financial instruments recognized through FVTPL Particulars MAT Impact MTM gains on financial instruments recognized through P&L Include in book profits MTM loss on financial instruments recognized through P&L Allowable from book profit Provision for diminution/impairment of Other Assets Includible under normal MAT provisions Gains/loss on financial instruments recognized (FVOCI) Amended MAT provisions

Dividend on Preference Shares on TD Ind AS treats preference shares as Liability and accordingly considers dividend on same as interest cost To add back dividend (incl. DDT) for MAT computation purpose IND AS Indian GAAP/AS NPBT 100 100 Less: Preference Dividend (10) (Interest) (10) (Dividend) Tax (30) (30) NPAT 60 60 Book Profit 90 100 Add: Preference dividend 10 - Profit as per MAT 100 100 Particulars

Revaluation amount on PPE & IA considerable for adjustment purpose i.e. gross amount or amount after depreciation adjustment - Book profit of the previous year in which items of PPE & IA are retired, disposed, realised or otherwise transferred shall be adjusted by revaluation amount after adjustment of depreciation on such revaluation amount AS/GAAP Ind AS (considering FV adj.) FV Adj. & corresponding depreciation 100 1000 900 Dep@10% for FY 15-16 10 100 90 WDV as on 01.04.16 90 900 810 9 90 81 81 810 729 Sale value as on 01.04.17 900 900 Profit on sale credited to P&L 819 90-729 819 819 Particulars WDV/Deemed Cost as on 01.04.15 Dep@10% for FY 16-17 WDV as on 01.04.17 MAT Adjustment Profit on sale to be considered for MAT

Others Particulars Remarks Impact of Deferred Tax on TD Ignore Impact of Provision for Bad & Doubtful Debts on TD Ignore Share application money pending allotment reclassified to Other Equity on Ignore Equity component on financial instruments included in Other Equity Covered under transition amount & hence taxable over the period of 5 years Whether deduction would be available for AY 201718 onwards in case b/f loss gets wiped off on adjustment of transition amount deduction of lower of depreciation or b/f losses shall be allowed based on 31.03.2016 figures & from subsequent periods as per Ind AS books of accounts

ACCOUNTANTS

Add: Borivali (W) :::: Sion (W) Tel No. 022-28910968 +91-9699710968 Website: www.snco.in Email Id: office@snco.in Disclaimer: Author has expressed his view on the subject and shared distinguishing rulings where-ever possible. Author shall suggest to take expert opinion based on facts of the case beside relying on decisions discussed on any of the topic