Latest developments in optimal structuring of
Inbound Investments including FDI, NRI
Investments –
FEMA and Taxation issues
CA N.C. HEGDE
5 July 2015
1
Discussion points
• Key decision metrics for inbound investments in India
• Forms of entity and funding alternatives
• Overview of Indian Exchange control and Tax regulations
• Recent developments impacting NR investments in India
• Parting thoughts
Structuring of Inbound investments in India
Key decision matrix
INDIA INBOUND
Growth rationale &
Mode
Ease of exit
Preferred
Industry &
Investment cap
Investment
Horizon, funding &
returns
Entity forms and &
Investment holding
These decisions are primarily functions of extant tax and regulatory
laws in India besides India’s political and overall socio-economic
landscape – Global tax initiatives like BEPS do also have bearing
3
Broad Tax & Regulatory framework impacting inbound
investments in India
EXCHANGE CONTROL
LAWS
(FEMA, FDI Policy)
INDUSTRIAL LAWS
(Industrial Disputes Act,
Factories Act)
EMPLOYMENT LAWS
(PF Act / Wages Act)
TAX LAWS
(Income Tax Act, Customs
Act)
INDIA BUSINESS
COMPANY LAW
(Companies Act, SICA)
COMPETITION LAW
SECURITIES LAWS
(COMPETITION ACT)
SCRA, SEBI, ICDR
IMMIGRATION LAWS
(VISA Regulations/
Passport Act)
Businesses in India require understanding of the interplay between various applicable
commercial laws –understanding of the civil and criminal laws become pertinent on specific
situations
4
Principal Forms of Business entities
Liaison Office (‘LO’)
• Acts as channel of communication
• Can’t undertake commercial activities
Limited Liability
Partnerships (‘LLP’)
• Any activity under automatic
route subject to specific
approval
LO
LLP
BO
Branch Office (‘BO’)
• Export / import of goods
• Professional service
• Representing parent
• Research activities
• No manufacturing
Forms of
entities
Unincorporated Joint Venture
(‘UJV’)
• Any activity subject
UJV (AOP)
to specific approval
Wholly Owned Subsidiary (‘WOS’) /
Incorporated Joint Venture (‘IJV’)
• Any activity subject to FDI policy
PO / SO
WOS / IJV
Project Office (‘PO’) /
Site Office (‘SO’)
• Execute specific projects
General funding alternatives
CAPITAL
FUNDING OPTIONS
Funds may comprise of equity /
debt / hybrid / depository
instruments
Own funds
EQUITY & QUASI EQUITY
Treated as own capital. Returns
by way of dividends /
consideration on transfer
EQUITY
Equity Shares
EQUITY
With differential voting rights
QUASI EQUITY
Preference shares
DEBT
Borrowed funds
DEBT
HYBRID
Treated as borrowed capital
Treatment will vary between
capital / debt
DEBT
Deposits, Promissory
notes issued
CCPS / OCPS
Quasi equity + Equity
DEBENTURES
Non Convertible
Debentures
Debt + Equity
LOANS
FCCB
Domestic loans / ECB
CCD/ OCD
Debt + Equity
DEPOSITORY RECEIPTS
Negotiable foreign currency
instruments with underlying
equity / debt
GDR
Instruments with Global
depository
ADR
Instruments with
American depository
IDR
Instruments issued by
Indian Depository
•
Indian Companies can issue capital / debt / hybrid instruments besides ADR /GDR / IDR subject to pricing guidelines /
valuation norms and reporting requirements
•
Issue other types of preference shares such as non-convertible, optionally convertible or partially convertible, which
have to be in accordance with the External Commercial Borrowings (ECB) guidelines
Price/Conversion formula of convertible capital instruments to be determined upfront at the time of issue
of the instruments
6
Profit repatriation alternatives
Options
Capital
Restructuring
Buyback of
shares
Dividend
Royalty / FTS
Interest
Cost sharing
arrangements
Overseas
investments
1. Jurisdiction analysis
2. Commercials
3. Tax considerations (local &
overseas)
4. Withholding tax obligations
5. Tax compliances
6. Regulatory implications
7. Transfer pricing
7
Gains from sale of CCDs in Joint Venture Company
by foreign partner to Indian partner amounted to
capital gains and not “interest” u/s 2(28A) Zaheer Mauritius – Delhi High Court
8
Zaheer Mauritius vs. DIT(IT) (Delhi – HC)
(1/3)
Facts of the case:
Assessee
(engaged in
construction and
development
business in India)
Mauritius
India
Vatika
(Engaged in the
business of
developing and
dealing in real
estate)
Entered into a Securities
Subscription Agreement (SSA)
and a Shareholder's Agreement
(SHA) with Vatika and the JV
Co.
JV Co.
(100% subsidiary of
Vatika)
Transferred interest in the land to the JV Co for
development of the land
Zaheer Mauritius vs. DIT(IT) (Delhi – HC)
(2/3)
Facts
• As per the SSA, the assessee agreed to acquire 35 per cent ownership interest in the JV Co by
subscribing to equity shares and Compulsorily Convertible Debentures (‘CCD’) of JV Co
• SHA provided for a call option given to Vatika - by the assessee; to acquire all the aforementioned
securities during the call period; and
• Likewise, a put option given by Vatika to the assessee to sell to Vatika all the securities during the
determined period
• Vatika partly exercised the call option and purchased a part of equity shares and CCDs from the
assessee
• The assessee filed an application before AAR seeking ruling on question of taxability of amount
received on sale of equity shares and CCDs
• The AAR held that the gains arising on the sale of CCDs being interest within the meaning of Section
2(28A) of the Act and Article 11 of the DTAA, was taxable as such
• Assessee filed a writ
10
Zaheer Mauritius vs. DIT(IT) (Delhi – HC)
(3/3)
Issues:
• The principal dispute between the assessee and the revenue was whether the
gains arising in the hands of the assessee from transfer of its investments in the
JV Co was 'interest' or 'capital gains‘
• Further, that the transaction between the assessee and Vatika is a sham
transaction and is essentially a transaction of loan to Vatika (camouflaged as an
investment in shares and CCDs of the JV Co)
Held that
• The terms of the arrangements between Vatika and the assessee revealed that
the JV was a genuine commercial venture, in which both partners had
management rights
• The call and put options were defined commercial options capable of being
elected by the parties
• There was no reason to ignore the legal nature of the instrument of a CCD or to
lift the corporate veil to treat the JV company and Vatika as a single entity
• In view of the above, the writ petition was allowed and the impugned ruling was
set aside
11
Overview of exchange control regulations in India
•
Consolidated Foreign Direct Investment (FDI) Policy
o FDI policy is formulated by the Department of Industrial Policy and Promotion (‘DIPP’),
Ministry of Commerce & Industry
o The DIPP regulates FDI through Press Notes (PNs) and now consolidated under the
Consolidated FDI policy which includes definitions
•
FEMA Notification and RBI Circulars
o The FEMA 1999 and FEMA Notification No. 20 is statutory framework / legal edifice which
enacts PNs
o RBI’s Master Circular (issued 1 July and updated from time to time), FAQs and Regular
Circulars
•
Portfolio Investment Schemes under FEMA ( Notification No. 20)
Portfolio Scheme is for NRIs, FIIs, QFIs, FVCI is distinct though they can also invest under FDI
Scheme
For FIIs, QFIs FVCIs and investments into listed companies IVCUs in
India, provisions of relevant SEBI regulations would additionally need to
be adhered to
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Foreign Investments in India – Schematic Representation
Foreign Investments
Foreign
Portfolio
Investments
Foreign
Direct
Investments
Investments
in LLP
Automatic
Route
Foreign
Venture
Capital
Investments
Investments on
non-repatriable
basis
Investments
made by QFI
NRI, PIO
SEBI
regd.
FVCIs
Govt.
Route
RFPI
FIIs
NRI, PIO
Persons
Resident
outside
India
Other Investments
(G-Sec, NCDs etc.)
FII
RFPI
AIF (VCF),
IVCUs
QFIs
NRI, PIO
The E-BIZ Platform recently launched by the DIPP is a step towards ease of doing business in India. Information
technology coupled with the intent of simplification of existing rules and approval process led to the integration of
14 services by Government ministries on the E- BIZ (Government 2 Business) portal
13
The transaction of routing FDI through the newly
interposed company is a colourable device not
permitted under the FDI Policy and FEMA
regulations –
IDBI Trusteeship Services Ltd vs. Hubtown
Limited - Bombay High Court
14
IDBI Trusteeship Services Ltd vs. Hubtown
Limited
Facts
•
•
•
•
•
•
•
Nederlandse Financierings- Maatschappiji Voor Ontwikkelingslandeo N.V.
(FMO), a Netherlands corporation held 10% of the shareholding + 3
Compulsorily Convertible Debentures (CCDs) in Vinca Developers Private
Limited (Vinca or Hold Co). The CCDs were convertible within a period of
60 months and upon conversion FMO would hold 99% of Vinca’s equity.).
The Hubtown Ltd. (Defendant) and individual promoters held the balance
90% shareholding in Vinca which was to be diluted upon conversion of the
CCDs.Tax office valued each equity share at Rs. 53,775 as against the
aforesaid valuation done under the Capital Issues (Control) Act, 1947
Vinca was involved in the construction development sector and had an FDI
eligible township project. Vinca had contractually agreed that the
investment by FMO would be used to purchase Optionally Convertible
Debentures (OCDs) issued by Amazia Developers Private Limited
(Amazia) and Rubix Trading Private Limited (Rubix), wholly owned
subsidiaries (WOS) of Vinca.
Accordingly, the amounts invested by FMO were infused into Amazia and
Rubix
The IDBI Trusteeship services Ltd. (Plaintiff) was Debenture Trustee in
regard to OCDs.
The Articles of Association (AoA) of Vinca were
amended such that FMO Nominee Directors on Vinca’s Board of Directors
would alone be entitled to take all decisions regarding the OCDs and the
Debenture Trustee.
The Defendant provided a guarantee in favour of Vinca for the
performance of the obligations by the Subsidiaries with respect to the
OCDs.
Upon failure by the Subsidiaries to make the payments on the
OCDs, the guarantee provided by Hubtown was invoked.
Subsequently, upon its failure to make the payments pursuant to the
invocation of the guarantee, the Debenture Trustee filed a petition for
winding up Hubtown and also a summary suit for recovery of the dues
which was sought to be defended by Hubtown.
NV FMO
10% Equity +
3 CCDs
(convertible
into 90%
equity
Outside India
India
VINCA
90% Equity +
Performance
Guarantee to Vinca
HUBTOWN
OCDS
100%
100%
RUBIX
AMAZIA
Debenture Trustee for OCDs
issued by Amazia/ Rubix
IDBI TRUSTEESHIP
SERVICES
15
IDBI Trusteeship Services Ltd vs. Hubtown
Limited
Issue
Where an Indian Company receives FDI and the proceeds are invested in OCDs of companies
operating in the construction development sector, such downstream investment by the FDI recipient
company violates the FDI Policy and FEMA regulations.
Ruling
Vinca was only a nominal recipient of investment from the foreign investor and the FDI amount was routed
by Vinca to Amazia & Rubix against issue by them of OCDs bearing a return of 14.5% per annum.
The downstream investment by Vinca in its subsidiaries was contractually predetermined. Since the foreign
investor could convert its CCDs into 99% shareholding in Vinca, in effect, the foreign investor would
receive an assured return on its investment, which was not permitted under the FDI regulations.
The FDI regulations only permit FDI by way of equity or compulsorily convertible instruments (CCDs) in
Indian companies. Accordingly, while the foreign investor could have directly invested in CCDs bearing
interest of Amazia and Rubix the amounts invested would be compulsorily required to be converted into
equity shares of Amazia and Rubix and the foreign investor could not have required Amazia or Rubix to
repay the amounts invested.
The Court, relying on the 2012 decision of the Supreme Court of India in Vodafone International
Holdings BV v. Union of India, held that whilst ascertaining the legal nature of the transaction it is the task
of the court to look at the entire transaction as a whole and not to adopt a dissecting approach. Further, a
device which was colourable in nature has to be ignored. In the present case, on facts, prima facie, the
structure was devised to circumvent the restrictions imposed by the FDI regulations.
While the ‘look at’ test was adopted by the Bombay High Court, the
judgment reflects that under such approach the courts are willing to
scrutinize the transaction and its various elements to ascertain if the
structure is in spirit compliant with the FDI Policy & FEMA
Regulations.
16
NRI Investments in India and Recent changes
9th January
every year is
celebrated
as NRI day
NRI Investment
Automatic route
with repatriation
benefits
Government
approval - FIPB
Repatriation basis
Other investment
with repatriation
benefits
Investment upto
100% equity
without
repatriation
benefits
Other investment
without
repatriation
benefits
Non repatriation basis
Amendment vide press note no. 7 (2015 Series) dated: 3-6-2015– NRI
investments on non repatriable basis in Schedule 4 deemed to be domestic
investment at par with investment made by Indian residents
17
NRI meaning & non-repatriable investments
better aligned for attracting more FDI
Meaning of NRI
• ‘Non-Resident Indian’ (NRI) means an individual
resident outside India who is a citizen of India or
is an ‘Overseas Citizen of India’
• The decision that NRI includes OCI & POI card
holders is meant to align parity in FDI policy with
NRIs in respect of economic, financial and
education field.
Investment by NRI’s on non-repatriable basis
• Non - repatriable investment made by NRIs,
OCIs and PIOs from their rupee account in
India, will not be treated as foreign investment
but as domestic investments
• The government has liberalized the FDI policy
for sectors such as Defence, Railways,
infrastructure, medical devices and insurance, is
keen to tap NRIs, OCIs and PIOs.
• Such amendment is brought to channelize the
funds of NRIs, who now have set up large
businesses abroad.
Amendment in FDI Policy
18
Forms of NRI Investments in India
PORTFOLIO INVESTMENT SCHEME
 Application to AD banker for investment in
Indian listed shares / convertible debentures
on repatriable / not repatriable basis
 Post one time permission by AD bank, NRI
may have permissible credits and debits in
his NRE/NRO/FCNR(B) accounts
 NRI investment ceiling in listed equity shares
 NRI investments under PIS cannot be gifted
to relatives / cannot be pledged for loan to
third party (without prior RBI approval)
INDIAN FIRM / PROPRIETORY
CONCERNS
Investment on repatriation basis subject to prior
Government of India / RBI approval
Investment on non-repatriation basis possible
by way of capital contribution if
i. amount invested via inward
remittance through normal banking channels or
NRE/NRO/FCNR (B) account debit
PURCHASE / SALE OF SHARES OR
CONVERTIBLE / NON
CONVERTIBLE DEBENTURES
 No limit on purchase on non-repatriation
basis through inward remittance of funds from
normal banking channels or
NRE/NR/FCNR(B) accounts
 Sale proceeds of shares / convertible
debentures to be credited to NRO account
 NRIs can invest in NCDs both on repatriation
/ non-repatriation basis
GOVERNMENT SECURITIES/PSU
BONDS / IDRs
 No limit on purchase on repatriation basis
Government securities, treasury bills, PSU
bonds, Domestic mutual funds, PSE shares
in accordance with disinvestment scheme
conditions
 IDRs issued in accordance with the
Companies Deposit Rules / SEBI ICDR
regulations, can be subscribed by NRIs
ii. Firm not engaged in agricultural / real-estate
activity
NRIs can pledge Indian company’s shares in favour of Indian AD banks / overseas banks in order to
secure credit facilities to the investee company / itself subject to prescribed conditions
19
Indian transfer pricing caution areas
Capital financing, including any type of long-term or shortterm borrowing, lending or guarantee, purchase or sale of
marketable securities or any type of advance, payments or
deferred payment or receivable or any other debt arising
during the course of business;
INTERNATIONAL TRANSACTIONS
ALSO LEADING TO TRANSFER
PRICING DISPUTES CURRENTLY
Transaction of business restructuring or
reorganization, entered into by an enterprise with
an associated enterprise, irrespective of the fact
that it has bearing on the profit, income, losses or
assets of such enterprises at the time of the
transaction or at any future date;
Share capital issuance / business reorganization transactions increasingly come under Indian
tax authorities scanner for demonstration of arms length principle - valuation critical for such
transactions for abundant caution against transfer pricing disputes
20
Amount received towards share premium from non
resident holding company does not give rise to any
income from an admitted International Transaction Vodafone India Services (P.) Ltd – Bombay High
Court
21
Vodafone India Services (P.) Ltd
Facts
•
The assessee was a wholly owned subsidiary of a non-resident company, Vodafone Teleservices (India) Holdings Ltd. (the holding company).
•
During relevant assessment year, the assessee issued shares of the face value of Rs. 10 each
on a premium of Rs. 8,509 per share to its holding company. The fair market value of the issue
of equity shares at Rs. 8,519 per share
•
Tax office valued each equity share at Rs. 53,775 as against the aforesaid valuation done under
the Capital Issues (Control) Act, 1947
•
The learned AO & TPO applied Chapter X and held that said amount of Rs. 1308.91 crores was
income.
•
As a result ,amount in question was required to be treated as deemed loan given by the
assessee to its holding company and periodical interest thereon was to be charged to tax as
interest income.
•
DRP upheld the AO order.
•
Assessee also filed the writ petition before the Bombay High Court challenging the ‘jurisdiction’
of the Union of India, TPO, AO and DRP (‘Respondents)’ to tax the issue of shares under
Chapter X of the Act
Issue
Whether issue of shares at a premium by assessee to its non-resident holding company does give
rise to any income as per transfer pricing provisions?
22
Vodafone India Services (P.) Ltd
High Court Ruling
•
‘Income arising from international transaction’ is condition precedent for application of Chapter X
•
Capital receipts not ‘taxable’ unless specifically included u/s 2(24) – e.g. capital gains
•
Share premium is taxable u/s 56(2)(viib) of the Act as is an income u/s 2(24)(xvi) – This is not
applicable in the instant case as it relates to issue of shares to “residents” only
•
Neither capital receipts received by Vodafone India on issue of equity shares to its holding company
nor alleged shortfall can be considered as income under the Act
•
By disclosing the transaction in 3CEB Vodafone India only ‘informed’ the tax authorities about the
transaction out of abundant caution to avoid penal consequences
•
The transaction of capital financing or business restructuring would be applicable to the extent it
impacts the income by under reporting of income and over reporting of expenses
•
On section 92(2) interpretation – Reading a provision by omitting words is not workable and not a
permitted mode of interpretation
•
Chapter X of the Act is a ‘machinery provision’ to arrive at ALP of an international transaction.
•
Charging provisions are section 4, 5, 15 (salaries), 22 (income from house property), 28 (Profits and
losses from business & profession, 45 (capital gain) and 56 (income from other sources)
•
Income arising from international transaction must fulfil the test of chargeability
•
“For all the above reasons, we find that in the present facts issue of shares at a premium by the
Petitioner to its non resident holding company does not give rise to any income from an admitted
International Transaction. Thus, no occasion to apply Chapter X of the Act can arise in such case”
23
Key Holding Company Jurisdictions for India investment
-
Treaty override is currently permissible. GAAR provisions proposed from 01.04.2017 restrict treaty override in case of
impermissible tax avoidance arrangements
Income stream
Mauritius
Netherlands
Singapore
Cyprus
Capital gains on sale of
shares
•
Nil
•
Nil
•
Nil
•
Nil (Subject to
substance tests)
•
No LOB provision.
However commercial
substance would be
essential in light of
BEPS
•
No LOB provision.
However commercial
substance would be
essential in light of
BEPS
•
Yes
•
No LOB provision.
However commercial
substance would be
essential in light of
BEPS
•
5% on foreign
currency
denominated debt
subject to fulfillment
of certain conditions
•
5% on foreign currency
denominated debt
subject to fulfillment of
certain conditions
•
5% on foreign currency
denominated debt
subject to fulfillment of
certain conditions
•
•
40% for Rupee
denominated debt
(including CCD)
10%, for Rupee
denominated debt
(including
CCD)provided the
recipient is the
beneficial owner of the
interest
•
•
15%, for Rupee
denominated debt
(including
CCD)provided the
recipient is the
beneficial owner of the
interest
LOB Provisions
Interest received from
Indian Companies
Dividend
Buyback of shares
10% on gross basis,
provided the recipient is
the beneficial owner of
the interest
•
Exempt in the hands of shareholders under the Act. However, company paying dividend, liable to pay DDT @20.36%
on divided paid
•
Exempt in the hands of shareholders under the Act. However, company paying buyback, liable to pay tax on buyback
consideration less amount received @23.072%
Cyprus is notified jurisdictional area for the purpose of Act – All transacting parties deemed to be associated
parties, transactions deemed to be international transactions, payments to Cyprus subject to withholding tax @
higher of 30% / rates in force / applicable rates as per provisions
India Mauritius DTAA under renegotiation primarily on LOB provision – Foreign investors bearish on Mauritius
route to India
24
BEPS Project – set to revolutionize international taxation
Base Erosion & Profit Shifting (BEPS) refers
to transaction maneuvering taking
advantage of tax rules difference leading to
double non-taxation or erosion of profit base
in the place of economic activity
Addressing BEPS critical to taxpayers and
governments across the globe to achieve tax
fairness and prevent national under-funding.
The purpose of the Action Plan is to prevent
double non-taxation, as well as cases of no
or low taxation associated with practices that
artificially segregate taxable income from
activities that generate it.
The BEPS project enlists 15 action points
which are targeted to be achieved by end of
2015
The focus areas include hybrid
instruments and entity forms,
treaty abuse provisions,
digital economy taxation,
transfer pricing implications
etc. through various modes of
reporting and automatic
information exchange
In India GAAR provisions
deferred for better alignment
with BEPS provisions as may
be accepted globally
Indian Government has laid considerable emphasis on automatic
information exchange to curb tax evasion and hence tracking key
developments around the BEPS project assumes significance –
BEPS & GAAR provisions to compliment each other
25
Recent developments impacting
Non Resident investments
Recent developments impacting NR investments
New Government’s scorecard
against Tax terrorism
Increased
reporting obligation
for foreign remittances
Deputation
Arrangements
in India
SEBI easing delisting &
M&A norms
(Buyback of shares) for ease
of doing business in India
Beneficial ownership test
material for treaty benefits
Look through and look at
approach
ICDS – a move towards
simplification or
complication?
Share issuance & transfer
pricing implications
Controversy around concessional
Long term capital gains
tax rate for unlisted securities
GST roadmap
All these aspects and many more which incessantly emerge pose opportunities and
challenges for business in India
27
Parting thoughts
Indian regulatory & tax landscape barometer
Continued liberalization of FEMA /FDI
Policy – ease for investors
Gradual delegation of powers by RBI to AD
banks for efficient and effective business +
governance results
Prolonged tax litigations with less effective
dispute resolution mechanisms
Multiplicity of enactment /amendments /
rules with ambiguity on implementation of
the same
Tax administrative reforms long awaited
Inclination of regulators and government authorities towards E-connectivity paves way for better
integration and casts onerous responsibility of true disclosures by business – teething troubles continue
29
Parting thoughts
POEM impacts foreign entities controlled from India
• PoEM has been defined in the Finance Bill, 2015 to mean a place where key
management and commercial decisions that are necessary for the conduct of the
business of an entity as a whole are, in substance made
• PoEM in India of the foreign company even for a part of the year could potentially trigger
residence based taxation in India on its global income @ 40% plus applicable surcharge
& cess
Black money Act implementation crucial
• Legislation seeks to levy tax and penalty on undisclosed income and assets by Residents
• Implications for Non Residents becoming Indian residents needs to seen in light of
existing and proposed disclosure norms
MAT on foreign companies still a point of concern
• Applicability of MAT to foreign companies continues to be debatable
• The Central Board of Direct Taxes or CBDT has issued a circular cautioning its field
officers not to issue fresh MAT notices or chase up aggressively on demand notices
already issued to allay concerns of the FIIs
• Justice AP Shah panel to present its report on the issue of MAT on FIIs
30
Parting thoughts
GAAR provisions deferred – boon or bane
• Implementation of GAAR has been deferred by a period of two years
• Will apply in relation to the investments made after March 31, 2017
Indirect Transfer provisions – some more clarity
• Any income accruing /arising whether directly or indirectly from transfer of capital asset
situated in India would be taxable in India
• The provisions of indirect transfer were introduced in 2012 to tax the transfer of shares
of foreign company, if such shares directly or indirectly derived ‘substantial’ value from
assets located in India
• The term substantial value clarified to mean value INR > 10 crores + representing at
least 50 % of the value of all assets of the company / entity
Foreign remittances – reporting broadened
• Effective 1 June 2015, the provisions of section 195 of the IT Act are amended to
provide reporting requirement to be applicable to any sum, whether chargeable to tax
or not, to a non-resident in a form and manner to be prescribed
Unlisted Indian companies also allowed to issue GDRs
• Depository scheme 2014 allows unlisted companies to issue GDR subject to FEMA
regulations
31
Questions?
32
Thank You
The information contained in this document is intended to
provide general information on a particular subject or
subjects and are not exhaustive treatment of such
subject(s).
The contents of this document are for general information
and the presenter by means of this document is not
rendering accounting, business, financial, investment, legal,
tax, or other professional advice or services. This document
is not a substitute for such professional advice or services,
nor should it be used as a basis for any decision or action
that may affect your finances or your business. Before
making any decision or taking any action that may affect
your finances or business, you should consult a qualified
professional advisor.
The presenter shall not be responsible for any loss
whatsoever sustained by any person who relies on
this document.
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