{"id":906,"date":"2024-04-23T04:59:30","date_gmt":"2024-04-23T04:59:30","guid":{"rendered":"https:\/\/theleagle.in\/?p=906"},"modified":"2024-04-23T04:59:32","modified_gmt":"2024-04-23T04:59:32","slug":"intersection-of-trusts-dtaas-and-it-act-1961-profile-of-adia-case","status":"publish","type":"post","link":"https:\/\/theleagle.in\/?p=906","title":{"rendered":"Intersection of Trusts, DTAAs, and IT Act, 1961: Profile of ADIA Case"},"content":{"rendered":"<div id=\"bsf_rt_marker\"><\/div>\n<p>Abu Dhabi Investment Authority (\u2018ADIA\u2019) is currently embroiled in a tax dispute in India that involves questions about its eligibility to claim tax benefit under India-UAE DTAA, recognition of foreign trusts in India, and interpretation of provisions of IT Act, 1961 on taxability of revocable trusts and their representative assessees. The Bombay High Court, in October 2021,&nbsp;<a href=\"https:\/\/taxguru.in\/wp-content\/uploads\/2021\/11\/Abu-Dhabi-Investment-Authority-Vs-Authority-for-Advance-Ruling-Bombay-High-Court.pdf\">held<\/a>&nbsp;that ADIA was entitled to avail the tax exemption under India-UAE DTAA despite ADIA making the investments and earning income through a trust registered in Jersey. The High Court held that AAR\u2019s ruling \u2013 against which an appeal was filed before the High Court &#8211; that ADIA was not entitled to tax exemption was erroneous. An appeal against the High Court\u2019s decision is currently pending before the Supreme Court. I rely on the High Court\u2019s judgment to highlight some of the novel questions that arise in the case.&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p><strong>Facts&nbsp;<\/strong><\/p>\n\n\n\n<p>The case involves Green Maiden A 2013 Trust (\u2018trust\u2019) settled in Jersey. ADIA was both the settlor and sole beneficiary of the trust while Equity Trust (Jersey) Ltd. was the trustee. Under its Deed of Settlement, the trust was a revocable trust and ADIA in its capacity as a settlor contributed two hundred million dollars in the trust. ADIA\u2019s reasons for settling the trust and using it for investment in India were that UAE did not offer a legal framework for settling trusts or incorporating a sole shareholder subsidiary company. Also, ADIA preferred making illiquid investments through separate legal entities which ensured it does not have to directly deal with portfolio companies. The trust through which ADIA made investments was registered with SEBI under the relevant Foreign Institutional Investor and Foreign Portfolio Investor regulations.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p>ADIA\u2019s case was that since the capital contribution made to the trust were revocable, any income earned by trust on investments made in India should be treated as income of ADIA itself. Under Article 24, India-UAE DTAA, any income earned by Government of one of the Contracting States is exempt from tax, and in case of UAE, Government includes ADIA. If the income of trust was treated as income ADIA, the income would be eligible for exemption under the said provision. The Revenue resisted such interpretation by arguing that the income was of the trust registered in Jersey and India-UAE DTAA could not be invoked, but the Bombay High Court rejected the Revenue\u2019s assertion.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p><strong>Relevant Statutory Provisions&nbsp;<\/strong><\/p>\n\n\n\n<p>Before I dig deeper into the issues and arguments, it is important to highlight the relevant provisions of IT Act, 1961:<\/p>\n\n\n\n<p>Section 61, IT Act, 1961 states that all income arising to any person by virtue of a revocable transfer of assets shall be chargeable to income tax as the income tax of a transferor and shall be included in his total income. Section 63, IT Act, 1961 states that a transfer shall inter alia be revocable if it in any way gives transferor a right to reassume power directly or indirectly over whole or any part of the income directly or indirectly. And Section 63(b) specifically states that transfer shall include a trust. Finally, Section 161(1)(iv), IT Act, 1961 states that a \u201crepresentative assessee\u201d means in respect of income which a trustee appointed under a trust declared by a duly executed instrument in writing whether testamentary or otherwise, receives or is entitled to receive on behalf, or for the benefit, of any person, such trustee, or trustees.&nbsp;<\/p>\n\n\n\n<p><strong>Arguments on Income and DTAA&nbsp;<\/strong><\/p>\n\n\n\n<p>ADIA\u2019s argument was that as per the Deed of Settlement, ADIA has the right to terminate the trust before end of its term, ADIA can re-assume power over entire income arising from investments in portfolio companies as well as principal amount in portfolio companies meaning that all capital contributions made or to be made by ADIA were revocable transfers under Section 63, IT Act, 1961. Thus, in view of Section 61, all income from investments made by trusts shall be chargeable as part of total income of the transferor\/settlor, i.e., ADIA.<\/p>\n\n\n\n<p>ADIA made an alternative argument and argued that even presuming Section 61 was inapplicable, under Section 161(1)(iv) the trustee, i.e., Equity Trust (Jersey) Ltd. can only be taxed \u2018in the like manner to the same extent\u2019 as the beneficiary. Thus, the income assessed in the hands of the trustee \u2018will take colour\u2019 of that of ADIA\u2019s income and will be eligible for exemption under Art 24, India-UAE DTAA. (para 14) The argument that the tax liability of the representative assessee is co-extensive with that of the assessee is on firm footing especially if one reads Section 166 whereunder the Income Tax Department is not barred from directly proceeding against the assessee. For example, it can proceed either against the trustee or beneficiary of a trust for recovery of tax. Either way, ADIA added, it is the beneficial interest in trust that that is taxable in the hands of the trustee and not the corpus of the trust. And more importantly, as per ADIA, any income for which the representative assessee\/trustee is liable is income of the beneficiary.&nbsp;&nbsp;<\/p>\n\n\n\n<p>The Revenue\u2019s arguments were that: first, there is no DTAA between India and Jersey, thus the trust which was settled in Jersey was taxable as a non-resident under IT Act, 1961; second, Indian Trusts Act, 1882 will not be applicable to foreign trusts though it conceded that there is nothing in the IT Act, 1961 which suggests that Sections 60-63, 161, 166 will not be applicable to foreign trusts; lastly, that ADIA would have been eligible for tax exemption under Art 24, India-UAE DTAA if it had invested in India directly.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p>The High Court decided in favor of ADIA by interpreting the relevant provisions of IT Act, 1961 strictly. I elaborate on the High Court\u2019s observations below.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p><strong>Recognition and Validity of Trusts&nbsp;<\/strong><\/p>\n\n\n\n<p>There were two major aspects regarding trusts that were discussed in the case: first, as per ADIA, Sections 61-63, 160, 161, and 166 do not expressly state that they are not applicable to foreign trusts; second, was whether the settlor of a trust can also be its beneficiary.<\/p>\n\n\n\n<p>The Bombay High Court approached the first issue in a straightforward fashion and noted that there is nothing in Sections 61 and 63 that restricts their applicability to foreign trusts and the argument that India has not ratified the Hague Convention on the Law Applicable to Trust and their Recognition does not resolve the issue one way or the other. (para 26) The High Court relied on&nbsp;<a href=\"https:\/\/itatonline.org\/archives\/cwt-vs-estate-of-late-hmm-vikramsinghji-of-gondal-supreme-court-important-principles-of-law-on-taxation-of-discretionary-specific-trusts-explained\/\">H.M.M. Virkamjit Singh Gondal<\/a>&nbsp;case to note that even foreign trusts are recognized under the IT Act, 1961. As regards the second issue, the High Court relied on&nbsp;<a href=\"https:\/\/indiankanoon.org\/doc\/1033621\/#:~:text=Hence%2C%20on%20the%20facts%2C%20taking,given%20to%20Bhavana%20Nalinkant%20Trust.\">Bhavna Nalinkant Nanavati<\/a>&nbsp;case to note that the only restriction on trusts is that the settlor cannot be the trustee&nbsp;<em>and<\/em>&nbsp;sole beneficiary of a trust, while in the impugned case the settlor \u2013 ADIA \u2013 was only a beneficiary and not trustee which is permissible.&nbsp;<\/p>\n\n\n\n<p>Once the applicability of IT Act, 1961 to foreign trusts was established, and correctly so, the High Court\u2019s other conclusions relying on other relevant judicial precedents were inevitable and resolved the issues satisfactorily.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p><strong>Merit(s) of High Court\u2019s Decision&nbsp;&nbsp;<\/strong><\/p>\n\n\n\n<p>The Bombay High Court\u2019s decision is laudable for evaluating the factual matrix appropriately and applying the relevant law. Since the decision is currently under appeal and pending before the Supreme Court, any comment on the outcome of the case is mere speculation for a distant observer. Nonetheless, a perusal of the Bombay High Court\u2019s decision reveals certain merits in its reasoning and conclusion.&nbsp;<\/p>\n\n\n\n<p>Most notable aspect of the Bombay High Court\u2019s decision is its engagement with the intent of Sections 60-64, IT Act, 1961, colloquially referred to as \u2018clubbing provisions\u2019. AAR, as per the High Court, had noted that the intent of clubbing provisions is to ensure that a taxpayer does not circumvent tax payments by ensuring that it does not receive income from a property but still retains control over that property. The High Court observed that AAR\u2019s observation that if ADIA had invested directly in India, it would have been exempt from tax does not appreciate why ADIA had not directly invested in India. The reason, the High Court noted, as been explained in detail by ADIA, was commercial expediency. Again, this is a correct understanding and optimum application of the relevant provisions to the commercial transactions. Clubbing provisions have an anti-tax evasion intent and are intended to prevent use of devices such as trust for tax evasion. But, if an entity is entering into commercial transactions which makes it difficult to obtain a tax benefit, then the commercial reasons for such transactions should be understood. However, acknowledging commercial reasons and commercial expediency is a tricky territory and needs to be navigated appropriately. The combination of facts in the impugned case justified High Court\u2019s conclusion, but commercial expediency cannot always be treated as sacrosanct to determine eligibility for tax benefits and may not be a prudent approach in all factual scenarios.&nbsp;&nbsp;<\/p>\n\n\n\n<p>Further, it is indeed novel that the Income Tax Department was emphasizing on the formal nature of transaction while the taxpayer was trying to underline the substance of it. The former was arguing that since the investment was made by a trust from Jersey, ADIA cannot claim tax exemption under India-UAE DTAA while ADIA was trying to emphasise that since it was the settlor of a revocable trust and its beneficiary, the income of Jersey trust was effectively ADIA\u2019s income. Typically, one witnesses the Income Tax Department trying to invoke substance of a transaction to justify taxation or recharacterize the transaction. The roles seemed to have reversed in the impugned case.&nbsp;&nbsp;<\/p>\n\n\n\n<p>Finally, the case also reflects the intricate nature of trusts and how determining their taxability is sometimes more peculiar than that of other forms such as corporates. The revocable\/irrevocable nature of trusts, their discretionary nature, foreign trusts, representative assessees all add layers that make their taxability an intricate affair, as in the impugned case.&nbsp;<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Abu Dhabi Investment Authority (\u2018ADIA\u2019) is currently embroiled in a tax dispute in India that involves questions about its eligibility to claim tax benefit under India-UAE DTAA, recognition of foreign trusts in India, and interpretation of provisions of IT Act, 1961 on taxability of revocable trusts and their representative assessees. The Bombay High Court, in &#8230; <a title=\"Intersection of Trusts, DTAAs, and IT Act, 1961: Profile of ADIA Case\" class=\"read-more\" href=\"https:\/\/theleagle.in\/?p=906\" aria-label=\"Read more about Intersection of Trusts, DTAAs, and IT Act, 1961: Profile of ADIA Case\">Read more<\/a><\/p>\n","protected":false},"author":2,"featured_media":907,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_themeisle_gutenberg_block_has_review":false,"cybocfi_hide_featured_image":"","footnotes":""},"categories":[137],"tags":[162,80,25,94,161],"class_list":["post-906","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-there-are-two-certainties-in-life-taxes-and-complaints-about-taxes","tag-adia","tag-bombay-high-court","tag-it-act-1961","tag-ravpratapsingh","tag-trusts"],"yoast_head":"<!-- This site is optimized with the Yoast SEO plugin v23.9 - https:\/\/yoast.com\/wordpress\/plugins\/seo\/ -->\n<title>Intersection of Trusts, DTAAs, and IT Act, 1961: Profile of ADIA Case - TheLeagle | Eco Law Forum<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/theleagle.in\/?p=906\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Intersection of Trusts, DTAAs, and IT Act, 1961: Profile of ADIA Case - TheLeagle | Eco Law Forum\" \/>\n<meta property=\"og:description\" content=\"Abu Dhabi Investment Authority (\u2018ADIA\u2019) is currently embroiled in a tax dispute in India that involves questions about its eligibility to claim tax benefit under India-UAE DTAA, recognition of foreign trusts in India, and interpretation of provisions of IT Act, 1961 on taxability of revocable trusts and their representative assessees. 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