Saturday, 15 June 2013

RELATED PARTY TRANSACTIONS

Related party transactions are those where two parties who share some common benefit in carrying out a particular transaction. This article will provide the definition, provisions and restrictions contained in Companies Act, Income Tax Act and Accounting Standards.
 The provisions, guiding the related party transactions are available under Section 297 of the Companies Act, 1956.
The Companies act does not define the term “related party” instead, it mentions the term “interest”.
The act restricts the contracts to be entered by the company with related parties. The company without the consent of the board cannot enter into contracts with a Private company or a firm where any directors/ relative of a director are interested in any way as a Director/partner/member of such private company. The following are the transactions:
1.      For sale or purchase or supply of goods and services
2.      For underwriting or subscribing to shares or debentures of the company.
So the contracting party should not be a PRIVATE COMPANY or a FIRM where directors are interested. And if the company has a paid up share capital of Rs. 1 crore or more it should get the approval of Central Government. 
If such a transaction is at prevailing market price or if the value of such a transaction is up to Rs. 5000 in aggregate in any year for the period comprised in the contract, the approval of the Central Government is not required.
In case of urgent necessity such contracts can be entered by the company without getting the approval of the board and within 3 months of entering into contract, the board’s approval should have been received.
For the purpose of related party transactions, the resolution of the board must be obtained “AT THE MEETING” and not by way of circular resolution.
Practical Procedure:[1]
Prior notice of the contract must be sent to the board members along with the agenda of the meeting.
During the board meeting, while considering the transaction, the interested director must stay away from the proceedings for that particular resolution.
What if?
If the consent of the board is not obtained to any contract then, anything done in pursuance of the contract shall be void at the option of the board.
Registers to be maintained:
Register under Section 301 - the provisions of this section mandates, the maintenance of a register detailing the contracts entered into by the company with the related parties. The same register must be placed at the meeting of the board.
Section 301(3) – register relating to the companies or firms in which directors are interested. This register must be entered with the details provided by the directors in Form 24AA as per Section 299(3).
“The intention of these provisions is to keep a check on the directors in carrying out the business of the company in their favor.
The act specifically restricts the transactions to be entered with a private company, as in most private companies the directors and members are one and the same.”
The Income tax Act disallows the expenditure incurred in respect of Related Parties, if in the opinion of the Assessing officer, the expenditure is excessive and unreasonable.
These expenditures are (a) the fair market value of goods, services or facilities for which the payment is made or persons (Related Parties) or (b) legitimate needs of business or profession of the assessee or (c) the benefit derived by or accruing to the assessee from the payment.
Income Tax act defines the following persons as a related party under section 40A (2)(b)
 (i) Where the assessee is any relative of the assessee; individual
(ii) Where the assessee is a any director of the company, company, firm, association partner of the firm, or member of of persons or Hindu undivided the association or family, or any family relative of such director, partner or member;
(iii) Any individual who has a substantial interest in the business or profession of the assessee, or any relative of such individual;
(iv) A company, firm, association of persons or Hindu undivided family having substantial interest in the business or profession of the assessee or any director, partner or member of such company, firm, association or family, or any relative of such director, partner or member;
(v) A company, firm, association of persons or Hindu undivided family of which a director, partner or member, as the case may be, has a substantial interest in the business or profession of the assessee; or any director, partner or member of such company, firm, association or family or any relative of such director, partner or member;
(vi) Any person who carries on a business or profession, - (A) Where the assessee being an individual, or any relative of such assessee, has a substantial interest in the business or profession of that person; or
(B) Where the assessee being a company, firm, association of persons or Hindu undivided family, or any director of such company, partner of such firm or member of the association or family, or any relative of such director, partner, or member, has a substantial interest in the business or profession of that person.
Explanation: For the purposes of this sub-section, a person shall be deemed to have a substantial interest in a business or profession, if - (a) In a case where the business or profession is carried on by a company, such person is, at any time during the previous year, the beneficial owner of shares (not being shares entitled to a fixed rate of dividend whether with or without a right to participate in profits) carrying not less than twenty per cent of the voting power; and
(b) In any other case, such person is, at any time during the previous year, beneficially entitled to not less than twenty per cent of the profits of such business or profession. “
“So, the probability of being taxed for such a related party transaction is in the opinion of the Assessing Officer. “
The Accounting Standard 18 (AS 18) issued by the ICAI, has the following provisions to be complied with respect to related party transactions. They must be disclosed by Companies in their financial statements.
[2]Definitions of various terms:
Related party - parties are considered to be related if at any time during the reporting period one party has the ability to control the other party or exercise significant influence over the other party in making financial and/or operating decisions.

Related party transaction - a transfer of resources or obligations between related parties, regardless of whether or not a price is charged.

 Control – (a) ownership, directly or indirectly, of more than one half of the voting power of an enterprise, or (b) control of the composition of the board of directors in the case of a company or of the composition of the corresponding governing body in case of any other enterprise, or (c) a substantial interest in voting power and the power to direct, by statute or agreement, the financial and/or operating policies of the enterprise.

 Significant influence - participation in the financial and/or operating policy decisions of an enterprise, but not control of those policies.

 An Associate - an enterprise in which an investing reporting party has significant influence and which is neither a subsidiary nor a joint venture of that party.

A Joint venture - a contractual arrangement whereby two or more parties undertake an economic activity which is subject to joint control.

Joint control - the contractually agreed sharing of power to govern the financial and operating policies of an economic activity so as to obtain benefits from it.

Key management personnel - those persons who have the authority and responsibility for planning, directing and controlling the activities of the reporting enterprise.

 Relative – in relation to an individual, means the spouse, son, daughter, brother, sister, father and mother who may be expected to influence, or be influenced by, that individual in his/her dealings with the reporting enterprise.

Holding company - a company having one or more subsidiaries.

Subsidiary - a company:
(a) in which another company (the holding company) holds, either by itself and/or through one or more subsidiaries, more than one-half in nominal value of its equity share capital; or

(b) of which another company (the holding company) controls, either by itself and/or through one or more subsidiaries, the composition of its board of directors.

Fellow subsidiary - a company is considered to be a fellow subsidiary of another company if both are subsidiaries of the same holding company.

State-controlled enterprise - an enterprise which is under the control of the Central Government and/or any State Government(s).

The standard describes the related parties as:-
1.      Enterprises that are directly or indirectly controlled by the reporting enterprise.
2.      Associate company or Joint venture and the investing party or venturer of the reporting enterprise.
3.      Individuals having a direct or indirect voting power in the reporting enterprise and relatives of such individuals.
4.      Key Management Personnel and their relatives
5.      Those enterprises where the persons mentioned in (4) & (5) have a significant influence and enterprises having common key managerial personnel.
The related party disclosures as defined in the accounting standard are not applicable when such disclosures would conflict with the reporting enterprise’s duty of confidentiality.
The term substantial interest means owning directly or indirectly 20% or more of the voting power of the reporting enterprise.
This standard requires that even if no transactions are carried out during a financial year, the relationship must be disclosed in the financial statements.
Spirit of this standard:
When there is no beneficial relation between two parties in a transaction, it is assumed that the transactions are carried out in an Arm’s Length Price. But when there exist any interest between the parties, the transactions might be charged at a price which is beneficial to them.  The resulting accounting measures may not represent what they usually would be expected to represent.
“These are the various provisions, to be complied, under various statutes with respect to related party transactions by a Company.” The Accounting Standard includes various parties as related to the company, while Companies Act requires the approval of Board of Directors or Central Government in certain cases. But under the Income Tax act, the power of taxation is with the Assessing officer, who must be satisfied in allowing the expenses carried out for the related party transactions.”
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[1] Source: on discussion with a Company Secretary of a listed company during one of my Secretarial Audit.
Refer section 300
[2] Source : Original text of accounting standard 18

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