If a partner’s contribution attracts tax, the manner in which the investment is structured could be significantly different as the contributing partner would require funds initially to meet the income tax liability. Devoid of such liability, partners would be free to structure the transaction as per their commercial negotiations.
Please click here to read the full article.
Kumarmanglam is an equity partner of the firm and also heads the direct tax and regulatory practice at JSA. He has more than 25 years of experience in matters relating to direct taxation (including international taxation, transfer pricing, litigation, anti-avoidance laws, and M&A tax), accounting, and corporate laws including mergers and acquisition, joint ventures, foreign investments, market entry strategy, and corporate restructuring.