Indirect Transfer - WIRC-ICAI

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Tax implications of Amalgamations & Demergers-JayeshSanghviJuly 2017Modes of M&A and Corporate RestructuringAmalgamation / MergerModes of M&A and Corporate RestructuringDe-mergerAcquisitionsAsset PurchaseShare PurchaseSlump SaleItemized SaleCapital Re-organizationBuy-backCapital ReductionConversionsLiquidation2Key Drivers of M&AWhy M&A?Achieve economies of scaleAcquisition of a competence or capabilityFinancial / Commercial/ Business restructuringAttract overseas investmentsDiversification -Entry into new market/ sector/ productOpening up of Economy3Key drivers for Corporate RestructuringSynergies of operations and cost efficiencySimplification of group structureSegregation of businesses and value unlockingCash neutralityRepatriation/ Upstreaming of fundsTax efficiency4Key Tax and Regulatory considerations under M&A and Corporate RestructuringcChanging Regulatory EnvironmentIncome Tax ActIndirect TaxesCompanies Act.

of its one or more undertakings to any resulting company in such a manner that— ... organization - Avaya Global Connect Ltd. Vs. ACIT (Mumbai Tribunal) 122 TTJ 300 •An undertaking should be interpreted to mean any venture or enterprise which a person undertakes to do-CIT v. Textile Machinery Corporation (Cal

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