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Case lawCBDT Circulars & Instructions › Statutory position — section 47(xvii) with section 49(2AC): swapping SPV shares for business trust units is not a transfer, and the gain is deferred to the sale of the units
CBDT Circulars & InstructionsCuts both wayss.47(xvii)s.49(2AC)s.45s.10(23FC)s.2(13A)s.115UAs.2(42A)

Statutory position — section 47(xvii) with section 49(2AC): swapping SPV shares for business trust units is not a transfer, and the gain is deferred to the sale of the units

My client is contributing his shares in a project company to a REIT and taking units in exchange. Is that a taxable transfer now?

My client is contributing his shares in a project company to a REIT and taking units in exchange. Is that a taxable transfer now?

No. Section 47(xvii) takes out of section 45 any transfer of a capital asset, being a share of a special purpose vehicle, to a business trust in exchange for units allotted by that trust to the transferor, so no capital gain arises on the swap itself. The charge is deferred rather than forgiven: section 49(2AC) provides that where a unit of a business trust became the property of the assessee in consideration of a transfer referred to in section 47(xvii), the cost of acquisition of the unit is deemed to be the cost of acquisition to him of the share, so the whole of the accumulated gain surfaces when the units are sold.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2015-04-01, reported as Clause (xvii) of section 47 and sub-section (2AC) of section 49, part of the business trust package introduced by the Finance (No. 2) Act, 2014 (Act No. 25 of 2014); text as printed on the Income Tax Department's section 47 and section 49 pages, each stamped Year 2024 (No. 1). It bears on section 47(xvii), section 49(2AC), section 45, section 10(23FC), section 2(13A), section 115UA, section 2(42A) of the Income Tax Act 1961, in Capital Gains, Charitable Trusts & Exemption, Capital Gains Exemptions and How Tax Law Is Read matters.

Still good law. Both provisions were read on the department's current section 47 and section 49 pages, each stamped Year 2024 (No. 1), each printing the correct section heading and naming the Income-tax Act, 1961; the surrounding clauses (xvi) and (xviii) and sub-sections (2AB), (2AD) and (2AE) were transcribed in sequence so that the clause labels could not be misread. The Bangalore Tribunal in Embassy Office Parks REIT v. DCIT, at its paragraph 25, refers to section 47(xvii) in the same terms as granting 'a specific exemption for the transfer of shares of a special purpose vehicle to a business trust in exchange for units of that business trust'. No page for either section stamped Year 2025 or Year 2026 was reached, and the footnotes attached to these provisions were not reached, so neither the commencement nor the absence of a later amendment has been verified from a departmental amendment note.

Why it matters

This is the provision that makes a REIT or InvIT formation possible at all, because without it the sponsor would face a capital gains charge on contributing project companies to the trust before he had received any cash. Four points decide how it works in practice. First, the exemption is confined to SHARES of a special purpose vehicle: a contribution of the underlying property, or of an interest in a limited liability partnership, or of debt, does not fall within the clause. Second, the consideration must be units allotted by that trust to the transferor — a swap partly for cash takes the transaction outside the clause on its face. Third, the Explanation to the clause defines 'special purpose vehicle' by reference to the Explanation to clause (23FC) of section 10, so the SPV must answer that description and not merely be a company the trust happens to acquire. Fourth, because section 49(2AC) substitutes the cost of the SHARE as the cost of the UNIT, the sponsor's eventual gain on the units is computed against a historic cost that may be decades old, and the holding period and the rate then applicable are those for a unit of a business trust and not those for the share. The Bangalore Tribunal in Embassy Office Parks REIT treats the very existence of section 47(xvii) as proof that shares and units are not the same species of property, which is a useful collateral use of the clause.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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Related

Other authorities on the same sections.