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Doing Business in India MUMBAI SILICON VALLEY BANGALORE SINGAPORE MUMBAI BKC NEW DELHI MUNICH NEW YORK Doing Business in India Considerations From a Switzerland- India Tax Perspective August 2018 © Copyright 2018 Nishith Desai Associates www.nishithdesai.com Doing Business in India Considerations From a Switzerland-India Tax Perspective August 2018 [email protected] [email protected] © Nishith Desai Associates 2018 Provided upon request only © Nishith Desai Associates 2018 Doing Business in India Contents 1. SWISS - INDIA RELATIONS: BACKGROUND 01 2. SWISS - INDIA TAX TREATY: SPECIAL CONSIDERATIONS 02 I. Residency of Partnerships and Hybrid Entities 02 II. PE Risks 02 III. POEM 02 V. Lower Withholding Tax Rate not Available to ‘Conduits’ 04 VI. Taxation of Capital Gains 04 VII. Exchange of Information 05 3. QUICK GUIDE FOR INVESTING INTO INDIA 06 © Nishith Desai Associates 2018 Provided upon request only © Nishith Desai Associates 2018 Doing Business in India 1. Swiss - India Relations: Background India’s traditional policy of non-alignment and the and Switzerland including: Swiss policy of neutrality, coupled with shared Swiss-India Joint Economic Commission (1959) values of democracy and rule of law have forged close §§ ties between the two countries. §§Swiss-India Collaboration in Biotechnology (1999) Swiss-India economic relationship dates back to §§Agreement for Avoidance of Double Taxation the 1850s, when Volkart Trading Co set up offices (1994, amended in 2000 and 2010) in Basel and Bombay. Since then, there has been a continuous rise in trade and investment flow §§Agreement for Promotion and Protection of between the two countries. Investments (1997) Switzerland is India’s 9th largest trading partner with §§Agreement on Social Security (2009) total bilateral trade including merchandise exports, Swiss-India Joint Committee on Science & bullion, IT services, and software export, amounting §§ Technology (2011) to approximately USD 20 billion in 2017-18.1 Swiss-India Financial Dialogue (2011) Switzerland is also India’s 11th largest investor, §§ accounting for approximately 1.14% of the total §§MoU on Mutual Cooperation in Local Gov- FDI in India from April 2000 to March 2018. In fact, ernance (2011) FDI from Switzerland into India is estimated to be approximately USD 4.31 billion during 2005 – 2016, §§MoU for Development Cooperation (2011) which is no surprise considering that over 250 Swiss Joint Declaration on the introduction of the companies have a presence in India either through §§ Automatic Exchange of Information on Tax their own subsidiaries or joint ventures.2 Keeping Matters (2016) in mind that much investment in India is routed through other countries, the Swiss National Bank §§Letter of Intent for Sister State Agreement actually estimates investment into India at a much between the State of Andhra Pradesh and the higher USD 7.71 billion during 2005-2016.3 Further, Canton of Zurich (2018) recent reform initiatives by India have created greater opportunities for Swiss companies especially in Further, the Swiss Embassy has taken a biennial sectors like clean technology, life sciences, precision initiative for 2017 and 2018 – “70 Years of Swiss- engineering, medtech, financial services and fintech, Indian Friendship: Connecting Minds – Inspiring construction materials and equipment, consumer the Future.” This initiative aims at presenting goods, railways and defense. To further boost FDI, cutting edge innovations where both Switzerland the Indian Embassy in Berne has also initiated the and India can mutually benefit. The new initiative “Momentum of India: Swiss SMEs Programme” which is in commemoration of the 70th anniversary of aims to facilitate the entry of Swiss SMEs into the the bilateral friendship treaty signed in 1948, and Indian market. will provide an excellent opportunity to further strengthen the good bilateral economic relations A number of bilateral agreements and institutional between the two countries. Such initiatives poise arrangements have also been executed between India India and Switzerland to see enhanced economic cooperation as well as an increase in trade and 1. Embassy of India, Berne, India-Switzerland Relations. Available investment flows. at: http://www.indembassybern.gov.in/page/india-switzerland/ 2. Id. 3. Id. 1 © Nishith Desai Associates 2018 Provided upon request only 2. Swiss - India Tax Treaty: Special Considerations I. Residency of II. PE Risks Partnerships Swiss companies having a PE in India would be and Hybrid Entities taxed to the extent of income attributable to such PE. It is necessary to take into account specific PE related Difficulties may arise when treaty benefits are tax exposure in the Swiss-India context. claimed by partnerships and hybrid entities. In addition to the standard PE threshold in most Benefits under the Swiss-India tax treaty treaties (eg: fixed base, office, branch, construction (“Swiss-India Treaty”) are available to site), the Swiss-India Treaty also has a service PE residents liable to tax in Switzerland. clause. A service PE may be constituted if services In Schellenberg Wittmer4, a Swiss general are provided by the Swiss enterprise’s employees partnership was held not to be entitled to treaty who spend more than 90 days (in a 12 month period) benefits since it is a fiscally transparent entity. It in India or 30 days if the ser vices are provided to a was further held that the Swiss resident partners related enterprise in India. of the partnership could also not take advantage A dependent agent in India of the Swiss enterprise of the treaty since they were not direct recipients that negotiates and concludes contracts on its behalf of the income. In contrast, the Bombay High Court would be treated as a PE. Unlike in most Indian confirmed that a German partnership (DIT v. Chiron treaties, an agent in India which manufactures or Bhering5) should be eligible for German-India tax processes goods belonging to the Swiss enterprise treaty benefits since the partnership (though fiscally would also be treated as a PE. This could create tax transparent) was subject to a German trade tax, exposure for enterprises having contract research which was listed as a covered tax under the treaty. and manufacturing arrangements in India. By virtue of a Protocol to the Swiss-India Treaty In eBay International AG v. ADIT8, the Tax Tribunal (effective from April 1, 2012), Swiss pension funds held that Indian company which entered into an or schemes would be treated as residents entitled to exclusive marketing services arrangement with treaty benefits even if they are gener- ally exempt its Swiss parent should not be viewed as a PE. from tax in Switzerland. This specific clarification The Tribunal also held that fees received by the provides some relief, considering that in the US-India Swiss entity from Indian customers who used the context, a US pension fund (in the case of Re: General online e-commerce platform is not in the nature of Electric Pension Trust6) was held not to be entitled to technical service fees and hence, not taxable in India treaty benefits.7 in the absence of a PE. III. POEM Another issue that arises is when an entity is treated 4. [2012] 210 TAXMAN 319 (AAR). as a tax resident under the laws of both countries. 5. TS-12-HC-2013 (BOM). 6. (2006)200CTR(AAR)121. Tax residence in a particular jurisdiction generally 7. Although the US-India treaty unlike most treaties recognizes attracts taxation of the worldwide income of the trusts, in this case it was not possible to establish that all beneficiaries of the trust (policy holders) were resident in the US. 8. [2013] 140 ITD 20 (Mum). 2 © Nishith Desai Associates 2018 Doing Business in India individual / entity concerned in that jurisdiction. The such employees comprise less than 50% of its India- Swiss tax treaty provides a tie-breaker rule to total payroll expenses (“ABOI Test”). address situations where an entity is a resident of both b. Foreign companies that do not meet the ABOI countries under their domestic laws, i.e., the entity will test are subject to a two-step test to determine be treated as resident of the jurisdiction where its place POEM. Step 1 involves the identification of of effective management (“POEM”) is situated. the persons who make the key commercial or These tie-breaker rules in the India-Swiss tax treaty management decisions of such company, while becomes important in light of the amendment step 2 involves determining the place where introduced in 2015 in India with respect to criteria such decisions are made. for determination of tax residence of companies c. The final guidelines for determination of incorporated outside India. Prior to this amendment, POEM also highlight that the approach for i.e., up to financial year 2015-16, a company determination of POEM is that of substance incorporated outside India qualified as an Indian tax over form and depends on the facts of each case. resident in a financial year (April 1 to March 31) only Accordingly, no single guiding principle will if the entire control and management of its affairs be decisive and various factors will have to be was wholly located in India during that financial taken into consideration to determine whether year. From financial year 2016-17 onwards, a foreign a foreign company has a POEM in India. company qualifies as tax resident in India if its POEM in the relevant financial year is in India. d. Certain administrative safeguards have also been included in the POEM final guidelines The Indian domestic law and the India- Swiss to ensure that senior revenue officers have to tax treaty (in the context of the tie-breaker be consulted before initiating an inquiry into rule) prescribe the same criteria (i.e., POEM) for the POEM of the entity. Further, the assessing determining tax residence of companies. However, officer is required to consult a collegium of it is important to note that the jurisprudence which senior officers before holding that the POEM of has evolved globally for determining where POEM a non-resident is in India.
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