Facebook’s USD 5.7 billion investment in Jio Platforms Limited: Advised Whatsapp Inc. (“Whatsapp”) in relation to its long-term commercial agreement with Jio Platforms Limited (“JPL”), Reliance Retail Limited (“RRL”), where Whatsapp will provide certain technology services to JPL for integration of WhatsApp’ software client and messaging and other application programing interfaces and Whatsapp payment services with Jiomart.com, which is owned and operated by RRL, with a view to enable Whatsapp consumer and business app users to purchase products and services from JioMart through such integration. We advised on the tax aspects in relation to the commercial agreement, on whether Whatsapp Inc. would constitute an e-commerce operator for purposes of income tax act. Our tax partner Ms. Gouri Puri and associate, Mr. Nimish Malpani worked on this deal.
Bain’s joint venture with Tiger Media: We advisedTiger Media Holdings (“Tiger”) on Bain Capital Credit through BCC Chill Aggregators LLC’s (“Bain”) investment in Tiger’s business of sourcing and licensing film and digital content. We advised on the setting up of a tax efficient holding company structure and intercompany agreements relating to business operations . Our tax partners Mr. Amit Singhania and Ms. Gouri Puri and associate, Mr. Nimish Malpani worked on this deal.
Adani’s acquisition of Krishnapatnam Port Company Limited: We advised the sellers on the sale of their stake in Krishnapatnam Port Company Limited (KPCL) to the Adani Group, for a deal value of USD 1.45 billion (approx.). The transaction entailed structuring the sale in light of parallel ongoing family settlement in the seller group and co-investor arbitration proceedings.Our tax partners Mr. Amit Singhania and Ms. Gouri Puri and associate, Mr. Nimish Malpani worked on this deal.
Farallon/Emami transaction – Advised Emami Group in relation to the issuance of non-convertible debentures (NCDs) by its certain group companies to Farallon Capital Asia Pte. Ltd. The terms of such NCDs issue were to be negotiated between the parties keeping in mind the investor’s interest of earning an optimum return on investment on the one hand and eligibility of such interest to the preferential tax treatment under the provisions of the domestic tax laws of India. We advised Emami group companies on withholding taxes in terms of eligibility of preferential tax treatment and assisted in structuring the transaction in a tax efficient manner. Our tax partners Mr. Amit Singhania and Ms. Gouri Puri and principal associate, Mr. Rahul Yadav worked on this deal.
DLF – Advised DLF in a major land consolidation exercise wherein it acquired shares of certain land owning companies. DLF group (through one or more of its affiliated entity) had an existing arrangement with such land owning companies regarding acquisition of development rights in respect of the underlying land parcels owned by such companies. The proposed transaction contemplated termination of existing arrangement and acquisition of such land owning companies from its shareholders. We advised DLF on the de-minimus valuation required under the provisions of the Income-tax Act, 1961 considering the anti-avoidance provisions under the law governing the valuation of immoveable properties and assisted DLF in implementing a tax efficient transaction structure. Our tax partners Mr. Amit Singhania and Ms. Gouri Puri and principal associate, Mr. Rahul Yadav worked on this deal.