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Minimum Alternate Tax!

Published on Fri, Apr 24,2015 | 22:18, Updated at Mon, Apr 27 at 16:57Source : CNBC-TV18 |   Watch Video :

Every year, India finds itself in a new tax controversy. The Vodafone litigation consumed the early years of this decade, capped by the retroactive tax amendment in 2012. Then came the Shell shock & transfer pricing trouble in 2013. Last year, the BJP made the UPA’s tax terrorism a campaign issue. Only to find itself now facing similar allegations. Over the last year or so, foreign portfolio investors have been asked to pay minimum alternate tax on past capital gains. The applicability of MAT on foreign companies is admittedly a vexed issue but few ever thought it would apply to foreign portfolio investors. Faced with requests for clarity, Finance Minister Arun Jaitley said in his budget statement, that hereon foreign portfolio investors will be exempt from paying minimum alternate tax on equity capital gains. But this prospective relief implies that past revenue demands are valid and thus, created a 40,000 crore rupees controversy! To discuss the applicability of Minimum Alternate Tax on FPIs, Porus Kaka, Bobby Parikh and Siddharth Shah join CNBC TV18’s Menaka Doshi this week on The Firm.

Doshi: My first question to you Bobby is if you can explain to us the magnitude of this foreign portfolio investor (FPI)- minimum alternate tax (MAT) problem. There are all kinds of numbers going around, going all the way up to Rs 40,000 crore. I do not know whether to give credence to any of these numbers because it is impossible to calculate. Is it a really big problem right now based on what your clients are telling you?

Parikh: So based on what our clients are telling us it is actually, it could become a very big problem. I do not know what the numbers add up to for this year. But the year that has been assessed to tax right now is the year of assessment 2012-‘13. So, there are ‘13-‘14, ‘14-‘15, ‘15-‘16; there are already three years of tax returns which have been filed which are still to be assessed and where the positions already established and they can go back another two three years so you have six, seven year period which all of these provisions would apply. The question is if they, how many of these investors come from Mauritius or from Singapore or from Netherlands or Spain or France or wherever there is an exemption and therefore position that seems to have been taken is that will not apply to those foreign institutional investors (FII). The MAT provisions are also not applied to FIIs which are not constituted as companies. So, two categories of FIIs are excluded from the scope of this action right now. Now how much does that leave and how large is that over a six or seven year period, it is not that easy to be able to model it but I would hazard a guess that it cannot be insignificant.

Doshi: So tens of thousands of crores.

Kaka: And one thing that I would like to say is that if you remember if you go back in time you must that for each year you go back, you have a 12 percent interest on that which is automatically added. And in three years that becomes near 50 percent of the tax. So as you go longer in period back, the greater and I have seen in some cases that when you are really talking about six, seven years, a significant part of the principle could get wiped out with just the interest liability.

Doshi: So, I want to go to the history of how this became a problem and that is MAT.

MINIMUM ALTERNATE TAX!

First levied in FY 1987-88
Withdrawn in FY 1991-92
Re-introduced in FY 1996-97

MINIMUM ALTERNATE TAX!

Section 115JB
Notwithstanding anything contained in any other provision of this Act, where in the case of an assessee, being a company, the income-tax, payable on the total income as computed under this Act…is less than 18.5% of its book profit, such book profit shall be deemed to be the total income of the assessee and the tax payable by the assessee on such total income shall be…at the rate of 18.5%

Kaka: I do not think there was any intention. It started out in 1997 and there in the finance minister’s (FM) speech itself, he makes it clear who it is applicable to and it clearly not non-domestic companies. So, when you go back in time it is clearly for widely held domestic companies and if you look at the provisions explaining that bill in 1997, it dealt with either deductions like depreciation or Chapter 6A where you really reduced your profits and did not pay tax. But at the same time, you had high dividend, etc profit making companies. It never dealt with the situation where you pay a tax like securities transaction tax (STT) which capital gains you actually pay and then it qualifies to be exempt under Section 10. So MAT was never intended for these purposes. What started out as a minimum alternate tax now with the removal for deductions on SEZs etc is become a thinking of a minimum tax. So, from the point of revenue it is clearly that MAT is now not an alternate, it is a minimum tax that you must pay irrespective of whether the item is already been taxed and therefore the exemption is given under Section 10 so no double taxation or whatever is the reason, you must pay a minimum tax.  

Doshi: But even in 1997, there was an authority for advance ruling (AAR) ruling the details of which I could not fully read because the ruling PDF is not available anywhere. But there was an AAR ruling that says that MAT does apply to foreign companies. But that specific ruling pertained to a company that had a business presence or a permanent establishment in India. So, I am trying to reconcile the fact that this seems like a recent controversy, but actually this question of whether MAT applies to foreign companies or not dates all the way back to 1997 when the provision was introduced.

Shah: That is correct. So, very clearly, applicability of MAT vis-à-vis the domestic entities and that was obviously the legislative intent with which the MAT was introduced where entities showing higher accounting profits. But not showing tax profits were the ones which were intended to be targeted. And that also to an extent included foreign companies which have a fixed place of business, permanent establishment in India and those entities to a great extent vis-à-vis their income in India would be treated at par with domestic entities. It was never intended to extend beyond that to cover foreign companies which may have investment income but have no investment, no presence in India or a permanent establishment.

Doshi: But the moment you open the door in 1997 itself, by saying that it applies to foreign companies that have with the caveat a business presence in India the fact that you are allowing for it to apply to foreign companies then becomes an established position from 1997 itself?

Shah: I would not tend to agree with that. The principal there was where essentially even if you are a foreign company but you maintain a place of business in India and earn income arising out of that place of business in India. To that extent you should not be treated any differently from any other domestic entity because as far as applicability of minimum alternate tax is concerned. But that still does not mean an extent that it would cover all foreign companies with no presence in India would be covered and treated at par with domestic entities to that extent.

Doshi: Would you agree with that Porus, because I am trying to understand whether the issue has snow-balled only now over the last three, four, five years especially because now because it is now FII or FPI involved or has it been the position since 1997 of the government maybe in unstated terms but definitely of authorities like the advance ruling authority that MAT does apply to foreign companies but with the caveat if you have a business presence in India. But foreign companies are included within the jurisdiction of MAT?

Kaka: No, when we reconcile the provision in that time, the question was how do you apply? Because MAT requires a certain computation provisions, it requires accounts to be prepared in a certain manner. The only requirement as far as foreign companies goes is if I recollect in that time was under the Companies Act if you had a place of business you were required to draw some part of your account up. So, therefore the only question was if you possibly had, it could only apply in those circumstances. In my opinion it was never intended to apply to foreign companies. It could apply at the maximum to companies who have to drop their accounts in accordance with either regulator or something under the Companies Act.

Doshi: Bobby, do you have a view on this?

Parikh: There are eight or nine rulings on this subject but some where companies have permanent presence on the grounds others where there is no presence on the ground. But there are no other judgements. So, it is not that there are only nine foreign companies that are operating in the country. So, it is not as if MAT is something which is a widespread issue, it is applied in every case, otherwise we would have had hundreds of judgements and hundreds of decisions and hundreds of cases going on all over the place. And the view of the AAR at the end of the day is binding on the tax department and on the tax payer for that case. Clearly none of the tax-payers otherwise seem to have taken that view. And neither has the tax department taken that view.

MINIMUM ALTERNATE TAX!

AAR, 1997
Foreign Company
Had Permanent Establishment in India

RULING: No reason to confine Sec 115JB to Indian companies alone

MINIMUM ALTERNATE TAX!

AAR, 2010
Praxair, Mauritius based company
Had Wholly Owned Subsidiary in India

RULING: MAT is not applicable to foreign companies which do not have any presence in India
                   Anyways Treaty benefits apply

MINIMUM ALTERNATE TAX!

AAR, 2010
Timken, US based company
No Permanent Establishment in India

RULING: Since Applicant does not have any business in India, there is no requirement for preparing its financial statements in accordance with the Companies Act, which is a fundamental requirement for levy of MAT.

MINIMUM ALTERNATE TAX!

AAR, 2012
Un-named Company, Panama based
No Permanent Establishment in India

COMMENTARY: Sec 115JB applies to all companies. Argument that a foreign company which is an investment company cannot comply with S 115JB since it has no other business in India may only mean the LTCG may itself become the book profit.

**No ruling for technical reasons

MINIMUM ALTERNATE TAX!

AAR, 2012
Castleton, Mauritius based

RULING: MAT applies to foreign companies as well. That the foreign company has no PE in India makes no difference to applicability of MAT. No reason to limit applicability of MAT owing to practical difficulties for foreign company to prepare accounts

MINIMUM ALTERNATE TAX!

Delhi ITAT, 2014
Bank Of Tokyo-Mitsubishi

RULING: MAT applicable only to domestic companies

MINIMUM ALTERNATE TAX!

Mumbai ITAT, 2010
Krug Thai Bank

RULING: Where a tax payer is not required to prepare its financials in accordance with Schedule VI of the Companies Act, MAT provisions should not apply.

Doshi: MAT has received mixed verdicts in the last 20 years. In 1997, the AAR held that MAT does apply to foreign companies. But in that case, the foreign company in question had a business presence in India. In 2010, in the Praxair case, the AAR held that MAT does not apply to a foreign company with no business presence in India. Praxair was also grated treaty benefits. In the same year, the AAR in the Timken case, reiterated its stance to say that since the US based applicant did not have any business in India, it did not need to prepare financial accounts in accordance with the Companies Act which is a fundamental requirement for the levy of MAT. But the position changed in 2012 when AAR chairman Justice Balasubramanian opined that Section 115JB applies to all companies and that if book profit computation cannot be done, the long-term capital gains may itself become the book-profit. But the AAR did not give any final ruling in this application due to other technical reasons. And that is why the 2012 Castleton decision by AAR is now what revenue relies on. Here, Justice Balasubramanian ruled that MAT applies to a foreign company irrespective of whether or not it has a business presence in India. He said that practical difficulties for foreign companies to prepare accounts as per the Companies Act is no reason to whittle down the scope of the section. There have also been two tribunal decisions pertaining to Indian branches of foreign banks and in both the tribunal bench is held that MAT was not applicable to foreign banks. In fact the Mumbai tribunal said, where a tax payer is not required to prepare its financials in accordance with Schedule 6 of the Companies Act, MAT provisions should not apply. Yet revenue prefers to wield Castleton extending it top foreign portfolio investors as well.

Kaka: Firstly, Castleton was not strictly an FII. So, to use that as the kind of, the torch-bearer would be firstly wrong. If you look at slightly later, even an ST company, the recording of the AAR is that the decision of Timken which is against the revenue which is accepted by the revenue and they are not challenging this position on MAT applicability. So, the question is really the revenue has to, AAR assesses may go for a certain comfort level, they may lose they may win, as Bobby said, it is not binding. But ultimately it is really for the revenue department. Did they intend MAT to apply to FIIs. If it was never intended to apply, it cannot probably have some cut off period as of 2015. It should have been done for all points in time.

MINIMUM ALTERNATE TAX!

Earlier
Company to prepare  P&L account in accordance with Companies Act, 1956

2012 Onwards
Company to prepare P&L account in accordance with Companies Act, 1956 or ..in accordance with provisions of the Act governing such company

Doshi: You are referring to the clarification in the Budget this time this time around.

Kaka: Correct.

Parikh: It is not a clarification; it is an amendment to the Act. It is not a clarification.

Doshi: And these are important words because that is what the government is going to rely on to be able to litigate this further.

Parikh: Clarification is very innocent. It is an amendment to the Act.

Kaka: But Bobby here I would still like to use the work clarification. Why? Because ultimately it must be the government’s intention. If they intend, again I am not speaking for the government, point is did you intend it or you did not intend it? If the answer is the latter, then it must be clarified.

Parikh: On this intention stuff because much has been made about the intention. From the time MAT was introduced in 1996, and the explanatory notes at that time said, “I propose to introduce a MAT in case where the total income the company has computed after availing all eligible deductions is less than 30 percent the total income of such company shall be 30 percent and will be chargeable to tax accordingly. The effective rate works out to 12 percent of book profits calculated under the Companies Act.” This is the explanatory memorandum when the MAT provision was introduced. 12 percent is derived by taking 30 percent and applying the rate of tax that was prescribed for domestic companies at that time which was 40 percent. The rate prevailing for foreign companies at that time was 55 percent. This is a very specific calculation.

Doshi: If foreign companies were to be included then they could not have arrived at 12.

Parikh: This is a effective rate of tax works out to 12 percent. This is in 1996. In 2000 he said when they made some changes to the provisions. The new provisions provide that all companies having book profits under the Companies Act prepared in accordance with part two and three of Schedule shall be liable to pay minimum alternate tax at a lower rate of seven and a half percent, as against the existing effective rate of 10.5 percent of the book profits. The 10.5 percent of the book profits again was 30 percent of the book profits and the prevailing rate for domestic companies which was 35 percent.

Doshi: So, you are saying that in the way they have calculated the tax rate they have only taken domestic companies into account therefore leading you to believe that foreign companies were never meant to be part of it.

Parikh: How much more clear do you want it to be? You do not have to lead yourself to believe. He is saying therefore the effective rate of tax is 12 percent or 10 and a half percent.

Shah: I definitely think from a policy and a legislative intent perspective and as Bobby laid out and Porus as well laid out, it was never intended to cover FPIs as a part of the MAT net. Look at it from a message perspective.

Doshi: You are making a distinction. You are saying FPI and not foreign direct investor (FDI). So, you are saying it might still cover FDI?

Shah: So, maybe we can we probably may have to deal with it because this issue can ultimately cascade into what all forms of foreign entities would get captured within it. So, for the moment even if you look at FPIs and generally as an intent when you are exempting long-term capital gains for investors. When you are reducing or withholding tax ion interest for foreign investors, all along it is very clear that you are not intending them to offer that income to tax at the rate of 12 percent because if that was the case, that intent should have been made very clear to foreign investors and that is legitimate expectation from foreign investors when they are investing into a country, that tax law should be certain. Now, keeping all of that in mind I definitely feel FPI as a category from a foreign portfolio investor perspective and looking at the way they operate in terms of where funds regularly trade invest, exit, their investors may re enter and exit at certain points in time; to now go back and say this was always the intent, to say that MAT was applicable to you, you should have offered that income though you claimed zero percent long-term capital gain stacks, you paid STT, but hang on you were to pay 20 percent tax and I think that is definitely unfair for the foreign investors and I would definitely hope that the minister would have clarified that as a part of the Budget rather than.

Doshi: Okay, I want to add Bobby did some calculations to show that the way this is worded and calculated, MAT was never meant to apply to foreign companies. The other argument has often been that to compute MAT, you have to compute book profits in a certain way under the Companies Act. If you were a foreign company, you never came under Schedule 6 of the Companies Act, therefore you could not compute those book profits in a certai way, therefore MAT could not have applied to you. In 2012 in the Finance Act they seem to have made an amendment to say that while you do not need to compute it in a certain particular way under the Companies Act thereby sending out a message saying even if you were a company that was not under the jurisdiction of the Companies Act in India, you would still have to compute book profits and you would still have to pay MAT. Would you say 2012 was the game changer here?

Kaka: I do not think so because that rectifies a situation where different companies within India prepare their account under different statutes because they were covered by different regulators, either the electricity companies, etc; they did not prepare it in accordance with. So, to cover that, 2012 really the amendment came. But the issue is the definition of Company I, the first part of the section that still remained the same. The point is that even today the foreign companies do not prepare any accounts in India at all whether under regulator A, B, C or D. They do not prepare anything. Secondly, if you will see the provisions of the section like subsidiary losses, things like that, they do not deal with a specific individual who has a transaction with India as opposed to someone who has a business in India. So, the whole objective of MAT is to look at kind of a parent company kind of a situation which is operating within a company and not with people who are transaction specific relations with India. Otherwise hypothetically if you receive a royalty at a lower withholding rate you should not receive a 10 percent rate, you should receive an 18 percent rate because that is a minimum tax. Forget the minimum alternate tax. So, we some how lose sight and today MAT has become what I call empty minimum tax. And that is wrong because even the legislature will have legitimate reasons for giving a lower withholding for interest, giving a lower withholding for royalty. You never intended then MAT to come back through the back door and make it 18 percent again.

Parikh: And the other thing is if 2012 was regarded as the door for…

Doshi: I am just asking because the law is brought up in some of the conversations that is happening.

Parikh: Fair enough. And the point to think about on that is that if it was really meant to say that therefore the way that amendment should be interpreted, is that if you are a company maintaining accounts under any other applicable law which means that if you are a foreign company and you are maintaining accounts per your applicable Companies Act, then those accounts will be the starting point for the purpose for the application of MAT. So, if I am a fund which is a global fund investing in multiple jurisdictions I might let us say I have funds on a corpus of USD 5 billion of which some amount might have been invested in India and the rest has been invested around the world. I do maintain accounts as per whatever is the local regulation. So, I will take those accounts which actually will reflect the investment results of investments activities of USD 5 billion of which let us say USD 1 billion has been invested in India. Now, I have profit let us say made on capital gains or whatever it is of USD 100 million on my entire corpus. That is my book profit. This requires me to say that okay, you have maintained accounts, you take those accounts, if we read that amendment in that way and you take that book profit and to that book profit you make the adjustments that are prescribed in the Income Tax Act which is this remove subsidiaries, remove some of those things, none of which will apply a foreign fund generally. And therefore if you have made USD 100 million of profit then you must pay tax, MAT tax on that USD 100 million although the Indian component on the USD 100 million might be USD 5 million, USD 10 million or might be zero or whatever it might be.

Doshi: So, maybe you have to compute the Indian component? Is that not how it is supposed to be?

Parikh: Now, where does that come out? If this amendment is saying that if you have maintained accounts as per any applicable law and if that was meant to cover a foreign company maintaining accounts as per its company law or whatever regulations that apply to it and if that has to be taken as the starting point, nowhere is, then there is no adjustment which says that you must adjust out of the book.

Doshi: So, my argument maybe fully flawed. I am just trying to get from ’96-’97, here is MAT, it does not apply to foreign companies at least explicitly it does not apply to foreign companies; to 2015 here is MAT it applies to everybody. I am saying how did we go to that distance? What happened?

Parikh: Correct. And the rates were always higher than the MAT tax so therefore you were paying tax and that tax was higher than MAT so, we never invoked MAT. It is in 2010 when the MAT rates went to 50, rose because MAT rates kept on going up and on the other hand the rate of tax on capital gains came down. So, short-term capital.
 
Doshi: So, that is when it became material to impose MAT.

Parikh: So in 2010 was when the MAT rate became 15 percent, my short-term capital gains were 15 percent but my long-term capital gains was zero. So, that is the first point at, that was an inflection point potentially where you could say that look now, your rates are lower, MAT is higher.

Doshi: And therefore MAT should apply. What is the feasibility of any of these FPIs or FIIs paying this tax actually. There have been several difficulties that have been raised over the last few months saying look these are profits going back to three and four years ago. We have redistributed those profits to our unit holders to our other investors. Now you are asking us to pay. Where do we bring out that money from? Funds may have closed down in that time or that specific sub-fund may have closed down. So I am just curious, how are they ever going to cough up this tax or does the tax department not care as in the Castleton ruling where the judge says that how you compute is not my problem, the difficulty is your problem.

Shah: Exactly and this has to be obviously looked at by the government from a larger perspective that is this something which is practically implementable for funds who may have wound up?

Doshi: Is it practically implementable? Your clients must be telling you whether it is practically implementable.

Shah: So, today funds which have been wound up who do you go after? Because, funds have a definite life. Directors, foreign directors, you will be basically proceeding against those directors to recover claims on income which was not earned by them. You are sending out a message to the world that we are the most difficult place to do business by giving such a hint.

Doshi: Curiously, Budget 2015 does not exempt FPI investments in debt from MAT nor does it exempt foreign companies or foreign venture capital funds or any other foreign transaction or payment. Will now MAT apply universally?

Kaka: From what little I have heard, if you are going to wait for Castleton to decide the answer is yes. But you have to clarify it for everybody else because you have taken a view that on the present wording however it is, it applies to foreign company, you mean the Government of India.

Doshi: So foreign companies, PE, FPI, royalty, fees for technical services all of this.

Kaka: You need to make it clear because if that is the intention, fine tell people upfront you have to pay minimum 18 percent tax in India and they will work.

Doshi: For the last seven years?

Kaka: That is the problem.

Doshi: For the last seven years? Actually, no.

Parikh: .. because fees for technical service and royalty that, well there was a period when it was 10, then they went back to 25, then they have come back to 10. So, it will be.

Doshi: So, yeah, okay. And all of this for foreign companies will apply prospectively as well because the exemption prospectively is only offered to FPI and equity.

Shah: That is correct.

Kaka: That creates a problem by itself because then you are carving out one sector for prospective. You have to take a policy view. Is MAT applicable to all companies and if so, then make it clear from the beginning that they have to pay 18 percent tax. Again this is a problem. We had these stray cases, Castleton, Timken. People wanting clarification, some lost, some won. But still I do not think even Bobby and they would have, it was not something of an industry view whether revenue went after every single foreign company with MAT. So, people were aware of it. It was in the background but the wisdom was that no, in all probability, you ought not to be liable. Now, there is a view that no you are clearly liable but prospectively you will not be liable. I just feel that there is something missing.

Shah: And again, just going back to the principle that you removed long-term capital gain stacks essentially at some level the intent was also to remove arbitrage on NTTs relying on treaties to basically encourage them to come and invest in directly into India. All you are doing now and if the current position that MAT is not being extended to treaty Jurisdictions. What is the message you are giving out to the world? Hang on I think you are still better off using treaties to that extent for investing into India and you are just giving out a conflicting message.

MINIMUM ALTERNATE TAX!

Country        % of FPI flow       Treaty Benefits
USA                   32%                      NO
Mauritius          22%                     YES
Singapore          8%                      YES
Luxembourg     8%                       NO
UK                    5%                       NO

Doshi: So is treaty protection valid in the current circumstances that we have discussed, both for FPI, FDI, FVCI? If you came from Mauritius or Singapore, etc would you be saved the wrath of MAT if I may call it that?

Shah: As things stand today, very clearly in terms of notices being issued out, a lot of them have not been issued to entities which have offered themselves to tax under the treaty. And the principle there being the Section 90 which also is a notwithstanding clause like 115JB. So, there are two notwithstanding clauses in that. So, to that extent as an assessee, if I have a choice to offer myself under Section 90 to say I will claim the benefits of a treaty, I am entitled to do so. And maybe that is probably the basis under which they may not have passed.

Doshi: So, Castleton is silent on whether MAT gets treaty benefits or not. The capital gains bit gets treaty benefits, that is what Castleton says. But all it says towards the end is that MAT applies to all companies, irrespective of the practical difficulties and that is it. It does not say whether you can claim treaty benefit on MAT. Can you claim a treaty benefit on MAT? Will the government give you that treaty benefit on MAT?

Kaka: I would think so because ultimately MAT is a part of the income tax statute. And normally in the definition of most of our treaties, you will define as to what is income tax meant. And it would be tax and anything which is similar and MAT is certainly a part of the Income Tax Act, so it would be covered by the treaty and therefore if the treaty gave you a relief on anything, it would cover a MAT provision also.

Doshi: So, it does not matter if you have a PE in India or not. It does not matter if your transaction took place on exchange or of exchange. It only matters if you come from a country which gives you treaty protection. If you do, if you happen to be from Mauritius, Singapore, Netherlands, then you are protected against the wrath of MAT. If you do not then MAT applies to you as well. Is that a fair understanding of the current problem facing FPIs?

(Section 90 deals with double taxation relief under treaties with foreign countries)

Parikh: As it stands right now, yes.

Doshi: As it stands. Okay. What judicial process does this go through now? Foreign portfolio investors will have to agitate all the way up to the Supreme Court, so we have to wait for a decision from the Supreme Court on Castleton.

Kaka: Castleton will work its way by itself. It is an opinion of an AAR. But all these investors will have to go either to the DRP or to the CITA and take that route, if there is one forte, they will go by way of writs to the high court. Going directly by way of a writ to the High Court looking at Vodafone’s experience when they went back to the DARP, they maybe a little reluctant, but again it is going to, this process is going to be time consuming, there is the mid demands, it is going to be quite unpleasant.

Parikh: This is now going to occupy and consume so much mind space of so many people around the world who have to figure out what they have to do. So, now we have issues of if I am a fund and I have this draft assessment order that has been issued. Should I be making a provision for this amount in my accounts so that means that it is a immediate NAV impact. Is it appropriate to make a provision for this thing and should I be providing for interest because I am not going to make a payment now, I am going to litigate it?  What is that liability going to work out to? There are penalty notices which have been issued so will I also get levied a penalty? Will I not? Some funds have received 147 notices for past years and the notice orderly at least the ones, some are that I have seen are only for one year. 2010-’11, so why not for the intervening years? No idea. It is even more confusing when there is so much inconsistency in the actions that are being taken because all of these things become matters of interpretation. There will be auditors involved, legal opinions, if I start creating provisions and then a few years later we find that this is not applicable then I will have mispriced units all the way through then I will misprice units again when I release this thing. Maybe it is small in the overall context of what that funds corpus is, maybe it is significant. So, how do you? So, is it a big issue? It is a big issue.

 
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