Direct Tax Code

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vikas chugh
Roll No: 114
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Table of Contents

Introduction………………………………………………………………………………...3

Minimum Alternate Tax (MAT)…………………………………………………………5

Test of Residency………………………………………………………………………….6

Tax treatment of savings-EEE V/S EET………………………………………………..8

Taxation of income from house property………………………………………………9

Taxation of capital gains…………………………………………………………………11

Taxation of income from employment – Retirement benefits and perquisites………14

Wealth Tax……………………………………………………………………………….16

Personal Taxation……………………………………………………………………….18

Comments………………………………………………………………………………...20

Annexure…………………………………………………………………………………21

Bibliography………………………………………………………………………………22

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INTRODUCTION

The draft Direct Taxes Code (DTC) along with a Discussion Paper was released on 12
August 2009 for public comments to simplify the direct tax legislation in India.
Subsequently, comments were solicited from the public and examined by the Government. A
Revised Discussion Paper was issued on 15 June 2010 to respond to the major concerns and
comments of stakeholders. Further, on 30 August 2010 a revised version of the DTC has been
tabled before the Lok Sabha. It is proposed to come into force on 1 April, 2012.

Key Highlights

 The Code on being enacted to come into force on 1 April 2012.

 The concept of assessment year and previous year to be replaced with financial year.
 Levy of surcharge and education cess to be done away with.
 Rates of tax applicable are proposed under a schedule to the Code, for companies the rate of
tax proposed is 30%.
 MAT of 20% applicable to a company if the tax under normal computation is lower than the
tax on book profit.
 A Foreign company to be liable to additional branch profit tax (BPT) of 15%. (irrespective of
whether the branch profits are distributed)
 No long-term capital gains tax, short term capital gains tax maintained at 15% on sale of
equity shares and units of equity oriented mutual fund subject to securities transaction tax.
Capital gains on other assets considered as income from ordinary sources and taxable at the
rate of 30%.
 Security transaction tax (STT) to continue.
 Wealth tax shall be payable at the rate of 1 percent on net wealth exceeding ` 10 million (as
against the earlier limit of ` 3 million).

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  Income Tax Act 1961 DTC-Initial Proposals DTC Revised

To be carried
Tax Losses forward Unlimited Carry forward Unlimited Carry forward
for maximum 8 years

Every Foreign Co. shall

Branch profit Tax No such Provisions be Branch profit tax @ 15%
additionally liable on all foreign companies
having any form of PE in
to pay @ 15% India

Foreign Companies If controlled and Resident in India where Rules Relaxed- Focus
even a part
-Residential Status managed wholly management shifted to place of effective
in India lies in India Management

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The following paragraphs provide an analysis of the proposals in the revised discussion paper
with the proposals made in original draft.

1. MINIMUM ALTERNATE TAX

Under the Income-tax Act, 1961 (the Act), a company is required to pay MAT at the rate of
18 percent of book profits, if the tax payable under the provisions of the Act is lower than the
MAT. MAT Credit is allowed to be carried forward for 10 years for set off against normal tax
liability.

Proposals in DTC

Under the DTC, it was proposed that a company shall pay tax on its gross assets at the rate of
2 percent (0.25 percent in case of Banking c

ompanies) if the tax liability under provisions of the DTC is less than the tax on gross assets.
The DTC did not provide for credit of such tax paid on gross assets. The economic rationale
for the assets tax is that investors can expect ex-ante to earn a specified average rate of return
on their assets; hence it provides an incentive for efficiency.

It has been proposed in the DTC that the "value of gross assets" will be the aggregate of the
value of gross block of fixed assets of the company, the value of capital works in progress of
the company, the book value of all other assets of the company, as on the last day of the
relevant financial year, as reduced by the accumulated depreciation on the value of the
gross block of the fixed assets and the debit balance of the profit and loss account if included
in the book value of other assets.

Issues with the proposed MAT on gross assets:

 Computation of MAT with reference to gross value of assets will require all companies
to pay tax even if they are loss making companies or operating in a cyclical downturn.
An asset based MAT on loss making companies would result in significant hardship
since they would not have the resources to pay the tax. While one “incentive for
efficiency‟ argument could be that such companies could shut down or restructure their
businesses, such an argument would not be valid for businesses where losses may be
inherent over long periods of the business cycle. Income tax should be on real income

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and any method for presuming income should also be reasonable enough to come closer
to the real income.
 An asset based MAT does not have a proximate linkage with a particular year's income
or turnover and will lead to significant hardship since companies would not have the
resources to pay the tax.
 The inclusion of “capital works in progress” which is not used in the business and does
not contribute in revenue generation would distort the asset based tax.
 The proposed MAT does not allow for any carry forward which would result in a
corporate paying more overall tax in a low profit year without there being any relief
against above average profits earned in a subsequent year.

Revised Discussion:

The government proposed in its revised draft of the Direct Tax Code (DTC) that the
Minimum Alternate Tax (MAT) would be computed on book profit of a company and not on
the gross assets because there may be practical difficulties and unintended consequences,
particularly in the case of loss making companies and those having a long gestation period.
The rate of MAT under the DTC bill is proposed at 20% on book profits.

The revised DTC draft says income of developers of special economic zones (SEZ) as well as
units therein will continue to get exemption under the proposed tax code. In the first DTC
draft released last August, tax exemptions were restricted to the developers of SEZ and not
the units in them.

Under the DTC Bill It is proposed that MAT Credit is allowed to be carried forward for 15
years for set off against normal tax liability.

2. TEST OF RESIDENCY

Under the Income Tax Act, a company is resident in India in any previous year, if the control
and management of its affairs is situated ‘wholly’ in India.

Proposal in DTC

The DTC provides that a company incorporated in India will always be treated as resident in
India. However, a company incorporated abroad (foreign company) can either be resident or
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non-resident in India. It has been proposed in the DTC that a foreign company will be treated
as resident in India if, at any time in the financial year, the control and management of its
affairs is situated “wholly or partly” in India (it need not be wholly situated in India, as at
present).

Issues

It has been pointed out that under the new test for determining residence in the DTC, a
foreign company whose control and management is partly in India will be treated as a
resident of India and thus liable for taxation in India on its global income. The word “partly”
used in the DTC sets a very low threshold for regarding a foreign company as a resident in
India. Apprehensions have been expressed that it could lead to a foreign multi-national
company being held as resident in India on the ground that some activity like a single
meeting of the Board of Directors is held in India. Also, a foreign company owned by
residents in India could be held to be resident in India as part of the control of such company
may be in India. It has been represented that this will result in uncertainty in taxation and will
impact foreign direct investment into India. Modification of the phrase “wholly or partly” has
therefore been suggested in the DTC Bill.

DTC Bill (Revised)

In case of a company incorporated outside India, the current domestic law is too narrow as
the test of residence of a foreign company is based on “whole of control and management”
lying in India. However a test of residence based on control and management of the foreign
company being situated “wholly or partly” in India as proposed in the DTC is much wider.

It is therefore proposed that a company incorporated outside India will be resident in India, if
its ‘place of effective management’ is situated in India

• Place of effective management of the company means –

– Place where the board of directors or its executive directors make their decisions or

– In cases where the board of directors routinely approve the commercial and strategic
decisions made by the executive directors or officers of the company, the place where such
executive directors or officers of the company perform their functions.

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“Place of effective management” is an internationally recognized concept for determination

of residence of a company incorporated in a foreign jurisdiction.

3. EET V/S EEE REGIME FOR SAVINGS SCHEMES

Under the Act, the long-term savings schemes like Government Provident Fund (GPF),
Recognized Provident Fund (RPF), Public Provident Fund (PPF), Life Insurance, etc. are
covered under the EEE method, wherein the contributions, accumulations / accretions thereto
and the withdrawals are exempt from tax.

Proposal in DTC

The DTC proposed to introduce Exempt-Exempt-Taxation (EET) method of taxation wherein

the contributions and accretions were exempt from tax, while the withdrawals were proposed
to be taxable. It was, however, proposed that only withdrawals of accumulated balances on
March 31, 2011 in specified Provident Funds would not be subject to tax.

Based on the EET principle, the Code provides for deduction in respect of aggregate
contributions up to a limit of Rs. 300000 to any account maintained with any permitted
savings intermediary, during the financial year. The permitted savings intermediaries will be
approved provident funds, approved superannuation funds, life insurer, and New
Pension System Trust. The accretions to the deposits will remain untaxed till such time as
they are allowed to accumulate in the account. Any withdrawal made, or amount received,
under whatever circumstances, from this account will be included in the income of the
assessee under the head 'income from residuary sources', in the year of such withdrawal or
receipt. It will accordingly be subject to tax at the applicable personal marginal rate of tax.

The permitted savings intermediaries would be approved by the Pension Fund Regulatory and
Development Authority (PFRDA). These intermediaries will, in turn, invest the amounts
deposited with them in government securities, term deposits of banks, unit-linked insurance
plans, annuity plans, bonds and securities of public sector companies, banks and financial
institutions, bonds of other companies enjoying prescribed investment grade rating, equity
linked schemes of mutual funds, debt oriented mutual funds, equity and debt instruments. The
choice of instruments will, in some schemes, be with the investor and in some others with the
trustees of the schemes. The pattern of investment by the latter will be as prescribed.

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Issues

Most countries that follow the EET method of taxation of savings also have a social security
system in place for all their citizens. In India, in the absence of a universal social security
system, the proposed EET method of taxation of permitted savings would be harsh.

Tax payers require some flexibility in making withdrawals in lump sum without being
subjected to tax. People may need lump sum funds on retirement for various family
obligations. Requests have therefore been made for continuation of Exempt Exempt Exempt
(EEE) method of tax treatment of investments. Alternatively, the application of EET should
be restricted to new savings instruments after the date from which the DTC comes into effect,
and it should not apply to existing saving instruments.

DTC Bill (Revised)

 It is proposed to provide the EEE method of taxation for Government Provident Fund
(GPF), Public Provident Fund (PPF) and Recognised Provident Funds (RPFs) and the
pension scheme administered by Pension Fund Regulatory and Development Authority.
 Approved pure life insurance products and annuity schemes will also be covered under
the EEE method

• Investments made before the commencement of the DTC in instruments which enjoy EEE
method under the existing Act, would continue to enjoy EEE method for the full duration
of the financial instruments.

4. TAXATION OF ‘INCOME FROM HOUSE PROPERTY’

Under the Act:

(a) House property is classified either as self occupied, let out or deemed to be let out

(b) The annual value of a House property deemed to be let out is determined with reference to
the ‘fair rent’ of the property.

(c) In case of properties let out / deemed to be let out, a deduction of 30 percent of the annual
value for repairs and maintenance is allowed.

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Additionally, interest on housing loan is allowed as a deduction

(d) In case of oneself occupied property, the annual value is Nil and an interest deduction up
to INR 1.5 lacs is allowed.

• The house is not actually let out in whole or in part.

• No other benefit is derived by the owner.

Proposal in DTC

(a) The gross rent from house property was proposed to be determined at higher of
contractual rent or presumptive rent. The presumptive rent was to be determined at the rate of
6 percent of the value fixed by the local authority or the cost of construction / acquisition of
house property, where no such value was fixed by the local authority

(b) Deduction for repairs and maintenance was restricted to 20 percent of the gross rent of the
property.

(c) No deduction was provided for interest on loan for a self-occupied house property.

Issues

The most frequent feedback on computation of income from house property has been the
determination of notional rent on presumptive basis (at the rate of 6%) with reference to
the cost of construction/ acquisition. The input is that this is inequitable as it
discriminates against recent owners as such cost is a function of inflation.

The other major issue which has been raised is that, in order to incentivize investment in
housing, the deduction for interest on capital borrowed for acquisition or construction of
a self occupied house property, up to a ceiling of Rs. 1.5 lakhs, as available in the
existing provisions of the Income-tax Act, 1961 should be retained.

DTC Bill (Revised Discussion)

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Taking the above factors into account, the following modifications are proposed:

 The concept of presumptive rent has been eliminated. Gross rent will not be computed
at a presumptive rate of six per cent of the rateable value or cost of
construction/acquisition.
 The removal of taxation based on presumptive rent is in line with the international
practice of taxing real / actual income instead of notional income.
 The deduction of INR 1.5 lacs in respect of the loan taken for acquisition /
construction of self occupied house property has been retained.

5. TAXATION OF CAPITAL GAINS

Discussion Paper on the Direct Taxes Code (DTC) provides that income from transactions
in all investment assets will be computed under the head "Capital gains”. The DTC provides
that gains (losses) arising from the transfer of investment assets will be treated as capital
gains (losses). These gains (losses) will be included in the total income of the financial
year in which the investment asset is transferred. The capital gains will be subjected to tax
at the rate of 30% in the case of non-residents and in the case of residents at the
applicable marginal rate.

Under the Code, the current distinction between short-term investment asset and long-
term investment asset on the basis of the length of holding of the asset will be eliminated.

• Indexation: In general, the capital gains will be equal to the full consideration
from the transfer of the investment asset minus the cost of acquisition of the asset, cost of
improvement thereof and transfer-related incidental expenses. However, in the case of a
capital asset which is transferred anytime after one year from the end of the financial year
in which it is acquired, the cost of acquisition and cost of improvement will be indexed
to reduce the inflationary gains.
(Under the existing Income Tax Act, in order to remove the impact of inflation the benefit of
indexation is given on long term capital gains)

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Base Year: The base date will now be shifted from 1.4.1981 to 1.4.2000. As a result,
all unrealized capital gains due to appreciation during the period from 1.4.1981 to 31.3.2000
will not be liable to tax as the assessee will have an option to take the cost of acquisition for
these assets at the price prevailing as on 1.4.2000.

The DTC also proposes that a new Capital Gains Savings Scheme will be framed by the
Central Government. Capital Gains deposited under this scheme will not be subject to tax till
the withdrawal from such scheme.

Revised Discussion paper:

 Capital gains to be treated as income from ‘ordinary sources’ for all taxpayers, including
non-residents and taxed at applicable rates.

 Capital Asset held for a period of more than one year from the end of financial year in
which asset is acquired.

(A) Listed equity shares or units of an equity oriented fund:

Capital gains arising from transfer of an investment asset, being equity shares of a company
listed on a recognized stock exchange or units of an equity oriented fund, which are held for
more than one year, shall be computed after allowing a deduction at a specified percentage of
capital gains without any indexation. This adjusted capital gain will be included in the total
income of the taxpayer and will be taxed at the applicable rate. The loss arising on transfer of
such asset held for more than one year will be scaled down in a similar manner.

Therefore if the “capital gains” before the deduction at the specified rate comes to Rs.100, it
would stand reduced to Rs.50 (if the specified deduction rate is 50 percent). This capital gains
would then be included in the taxpayer’s total income and taxed at the applicable rate. In this
example, for a taxpayer in the tax bracket of 10%, such gain will bear an effective tax at the
rate of 5% and for taxpayers in tax bracket of 20% or 30%, the effective tax rate would be
10% or 15% respectively.

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The Table below gives examples of the effective rate of taxation for different taxpayers at
different specified rates of deduction:

(B) Gains from transfer of other investment assets held for more than one year:

In respect of other investment assets held for more than one year from the end of the financial
year in which these were acquired, the indexation benefit would be available with reference
to the base date of April 1, 2000. However, deduction at specified percentage will not be
allowed.

(C) Gains from transfer of assets held for less than one year

In respect of assets held for less than one year from the end of the financial year in which
these were acquired, capital gains will be computed without the benefit of either a specified
deduction or indexation. It will be included in the total income and will be charged to tax at
the rate applicable to taxpayer.

(D) Capital gains in the hands of FIIs

Income arising on purchase and sale of securities by an FII shall be deemed to be income
chargeable under the head ‘capital gains’. Further, such gains arising to FIIs shall not be
subject to TDS and FIIs would be required to pay advance tax on such gains.

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6. TAXATION OF RETIREMENT BENEFITS

Under the existing Income Tax Act, the amount received by an employee on account of
gratuity, commutation of pension, leave encashment, voluntary retirement at the time of
retirement / termination is not taxable, subject to specified limits.

Under the existing Act:

• Any commuted pension is exempt for Govt. Employee

• Any commuted pension received by non Govt employee is exempt as follows

i) If receiving gratuity 1/3 rd of commuted value

ii) If not receiving gratuity ½ of commuted value.

Proposal in DTC

The DTC provided that amount received by an employee towards gratuity, commuted
pension and voluntary retirement will not be taxable only if the same is deposited in a
Retirement Benefit Account (RBA) maintained with the permitted saving intermediary

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prescribed by the Central Government. However, leave encashment is taxable on receipt

basis. Further, any withdrawals from RBA were subjected to tax in the year of withdrawal.

The Discussion Paper states that the value of rent-free accommodation will be determined for
all employees including Government employees in the same manner as is presently
determined in the case of employees in the private sector. So valuation of rent free
accommodation in the following manner:

Component Description

Accommodation Owned by the employer

15% of salary (in cities having population exceeding twenty-

five lakhs)

10% of salary (in cities having population exceeding ten

lakhs but not exceeding twenty-five lakhs)

7.5% of salary in any other place

Leased by the employer

15% of salary; or

actual rent paid; whichever is lower

Hotel accommodation

24% of salary; or

actual charges; whichever is lower

Issues:

Representations have been received from stakeholders that in the absence of adequate social
security benefits, the social and economic norm is to use retirement benefit amounts for

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savings as well as for social expenditure. Hence, taxation of withdrawals from a Retirement
Benefit Account would be harsh.

If the value of accommodation in the case of government employees will be taken at market
rent, it would create a high tax burden.

DTC Revised

Maintaining individual Retirement Benefits Account by permitted savings intermediaries on

behalf of all employees would require a centralised nationwide authority to regulate and
manage crores of retirement benefits accounts of employees and to deduct tax on withdrawal
which entails creation of a separate institutional mechanism, complex logistics, and
substantial costs. The complexity of maintaining permitted savings accounts has been
discussed in the context of the EET method of taxation. For the same reasons, it is proposed
not to introduce the Retirement Benefits Account scheme.

Current tax regime to continue and amounts received by an employee towards gratuity,
commuted pension, and voluntary retirement and leave encashment will continue to be
exempt, subject to specified limits.

DTC Bill states that perquisite value of rent free accommodation will not be calculated based
on market value.

Tax exemption for retirement benefits is a welcome step and will mitigate undue
hardship to employees.

7. WEALTH TAX

Existing Act:

The Wealth-tax Act, 1957 provides for wealth tax at the rate of 1 percent on specified assets
exceeding INR 3 million. Wealth-tax is levied on Individuals, Hindu Undivided Family
(HUF) and Company.

Proposal in DTC

Under the original DTC draft, wealth-tax will be payable by an individual, HUF and private
discretionary trusts. It will be levied on net wealth on the valuation date i.e. the last day of the

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financial year. Net wealth is defined as assets chargeable to wealth-tax as reduced by the
debt owed in respect of such assets. Assets chargeable to wealth-tax shall mean all assets,
including financial assets and deemed assets, as reduced by exempted assets. Exempted assets
include stock in trade, a single residential house, or a plot of land etc. The net wealth of an
individual or HUF in excess of Rs. 50 crore shall be chargeable to wealth-tax at the rate of
0.25 per cent.

Issues:

The threshold limit of Rupees 50 crore for levy of wealth tax is too high.

On the other hand it has also been argued that tax on financial assets will be harsh as they are
currently exempt.

DTC Revised:

 Every person, other than a non-profit organization, shall be liable to pay wealth tax
 Wealth tax shall be payable at the rate of 1 percent on net wealth exceeding Rs. 10
million (as against the earlier limit of Rs. 3 million)
 Definition of “specified assets” shall include (among other things) the following items:
 Building or land appurtenant thereto farm house situated in the specified areas
 urban land
 motor car, boat, helicopter
 Jewellery, bullion, etc.
 archaeological collections, drawings, paintings, sculptures,
 watch having value in excess of Rs. 50,000,
 cash in hand exceeding Rs. 200,000,
 Equity or preference shares held in a Controlled Foreign Company, etc.

Certain exemptions have been provided, such as residential houses allotted to employees,
houses occupied for business purposes, etc.

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8. PERSONAL TAXATION:

TAX SLABS

 The DTC proposes to increase the limit of income exempt from tax to 2 lakh from the
current 1.6 lakh for individual and to 2 lakh from 1.9 lakh for working women. This will
result into a minimum saving of 4,000 per annum for individuals and 1,000 per annum for
women.
On the positive note, the new proposal aims to abolish the distinction between the individual
and a women tax payer, bringing both of them at par — at least as far as payment of taxes is
concerned. But given the rising cost of living with each day, an additional disposable income
of about 4,000 and 1,000, respectively, does not sound much appealing.
Moving higher on slab rates, income falling between 2 lakh and 5 lakh will now attract a tax
rate of 10% while that falling between 5 lakh and 10 lakh will be taxable at 20%. This
proposal, if implemented, will replace the current tax structure where income falling between
1.6 lakh and 5 lakh is taxed at 10% while that between 5 lakh and 8 lakh is taxed at 20%.

Thus, there is a marginal relief for those who have income between 8 lakh and 10 lakh. The
DTC also proposes to raise the income slab rate, which attracts the maximum tax rate of 30%
from the current 8 lakh to 10 lakh. The maximum amount that a tax payer can save, if the
DTC proposals are approved in its current form, is `24,000 per annum.

DEDUCTIONS: 
Under the current tax laws, Section 80C is probably one of the most popular sections of the
Income-Tax Act as it allows a deduction up to 1.2 lakh from the taxable income if the same
has been invested productively in selected investment avenues. The DTC has not only
proposed to retain the structure but also enhanced the limit of the deductions up to `1.5 lakh.
It has, however, modified the basket of investment avenues eligible for deduction under this
clause.

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The DTC proposes to include only contribution to funds like PPF, PF, superannuation fund
and the New Pension Scheme (NPS), up to a maximum of `1 lakh, as eligible investments for
deduction under this clause. An additional deduction of 50,000 shall be allowed for payments
made towards insurance premium, tuition fees and premium paid towards mediclaim.
Thus, the current deductions under Section 80D with respect to mediclaim premium up to
15,000 for self and an additional 15,000-20,000 for dependent parents shall stand redundant
once the new DTC comes into play with the maximum amount of deduction for mediclaim,
insurance premium and tuition fees being restricted to 50,000 only.
What also falls out of the investment ambit is the tax-saving mutual fund schemes (ELSS),
unit-linked insurance plans and the five-year tax saving bank fixed deposits. In fact, equity
mutual funds and Ulips shall now attract a dividend distribution tax (DDT) of about 5% if the
current proposals are accepted. This means that any income received as dividends from
equity mutual funds and Ulips will be taxed at 5%.
The DTC proposals also raise doubt about the prospects of infrastructure bonds which were
introduced by the finance minister earlier this year, promising an additional deduction of
`20,000 with respect to investment made in these bonds as the current proposals are silent on
this front.
The proposals continue to allow deduction on interest repayment of up to 1.5 lakh on housing
loans. But the new code has done away with the deduction on repayment of principal on such
housing loan, which is currently admissible under Section 80C up to a maximum sum of 1
lakh.
EXEMPTIONS: While there is nothing much to rejoice as far as the reorientation of tax slabs
and deductions from income are concerned, the DTC proposal to increase the limit of medical
reimbursement will bring in some cheer. With medical expenses going off the roof, the DTC
proposes to enhance the limit of reimbursement made by an employer for medical expenses
incurred by an employee from the current 15,000 to 50,000. DTC is also set to introduce an
allowance payable by an employer to an employee to meet his personal expenses.

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Comments:

Key negative of original paper rolled back – MAT to remain profit-based

The bill proposes MAT rate of 20% of adjusted book profit, compared to 19.93% (with
surcharge) of adjusted book profit currently. The original draft had proposed MAT to be
investment-based rather than profit-based. It was suggested to levy MAT of 2% on gross
assets for non-banking companies and 0.25% of gross assets on banking companies. By
reverting to profit-based MAT, the bill has provided relief to the companies with genuine
losses or sub-optimal RoCE due to initial or cyclical downturn, as they may have been
negatively impacted by the move to investment-based MAT. But there is no relief in the
payment of MAT as it has been proposed at a rate of 20% as against current rate of 19.93%.

Tax slabs have been relaxed marginally so it will not be very much beneficial for a normal
individual.

Corporate Tax:

Under the original discussion paper, it was proposed to reduce the corporate tax rate from
about 33% to 25%. However, the new bill proposes only the removal of surcharge,
effectively reducing the tax rate to 30%. This is a marginal positive for the Indian companies,
which is explained in the following table by taking examples of some companies:

Corporate tax

Current @ 33.99% Proposed @ 25% initially Proposed @ 30%

IOC 3815 2806 3367
Tata Steel 1998 1470 1763
ITC 2062 1517 1820
ACC 673 495 594

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ANNEXURE

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Bibliography:

finmin.nic.in

incometaxindia.gov.in

www.delloite.com

Economic times (Tuesday, 31 August 2010)

www.pwc.com

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