Applicability of Minimum Alternate Tax (MAT) to Public Limited Companies
Introduction
Minimum Alternate Tax (MAT) is a provision introduced under the Income Tax Act, 1961 to ensure that companies, including Public Limited Companies, pay a minimum amount of tax even when they claim significant deductions and exemptions that reduce their taxable income. MAT is levied on the book profits of companies when the normal tax liability is lower than a specified threshold. The objective is to bring equity in the tax system and prevent tax avoidance. This article explains the applicability, calculation, exemptions, and implications of MAT for Public Limited Companies in India.
Legal Basis of MAT
MAT is governed by Section 115JB of the Income Tax Act, 1961. It applies to all companies, whether private or public, listed or unlisted, that are registered and operating in India. MAT ensures that a company that reports profits in its financial statements but pays little or no tax due to various incentives must pay a minimum level of tax based on those book profits.
Who is Liable to Pay MAT
A Public Limited Company is liable to pay MAT if:
- The income tax payable under the normal provisions of the Act (based on taxable income) is less than 15% of its book profit.
- In such cases, the company must pay 15% of the book profit as MAT, plus applicable surcharge and 4% health and education cess.
Calculation of Book Profit for MAT
Book profit is calculated based on the net profit as per the company’s profit and loss account prepared in accordance with the Companies Act, 2013, adjusted for certain additions and deductions specified under Section 115JB. Common adjustments include:
- Adding back provisions for income tax and deferred tax
- Deducting income exempt under Section 10AA or SEZ benefits
- Adjustments for revaluation reserves or depreciation differences
MAT Credit and Carry Forward
If a Public Limited Company pays MAT, it is eligible for MAT credit to the extent the MAT paid exceeds the normal tax liability. This credit can be carried forward for up to 15 assessment years and can be set off in future years when the company’s normal tax liability exceeds MAT.
Exemption from MAT under Special Tax Regimes
Public Limited Companies opting for the concessional tax regimes under:
- Section 115BAA (22% tax rate), or
- Section 115BAB (15% tax rate for new manufacturing companies)
are exempt from the applicability of MAT. This encourages companies to adopt simpler tax regimes with fewer exemptions but lower overall tax burdens.
Non-Applicability to Certain Income
MAT is not applicable to income earned by a company from:
- Life insurance business (covered under Section 115B)
- Shipping income (covered under tonnage tax scheme)
Additionally, companies earning income from infrastructure development or engaged in international financial services centers (IFSCs) may be eligible for partial relief or lower MAT rates.
Impact on Financial Planning
MAT affects financial planning and tax forecasting for Public Limited Companies. Companies must consider MAT while availing tax holidays, depreciation, and deductions, as even low taxable income may attract MAT liability. It also impacts dividend declarations, cash flows, and tax provisioning.
Reporting and Compliance
Companies liable to MAT must:
- Calculate MAT accurately along with their regular income tax
- Disclose MAT liability in their financial statements
- Maintain detailed records for MAT computation and MAT credit
- File relevant details in the income tax return (ITR-6) and Form 29B certified by a chartered accountant
Conclusion
Minimum Alternate Tax is a safeguard mechanism ensuring that profitable Public Limited Companies contribute a minimum level of tax to the exchequer. Though it imposes an additional burden in years of high deductions or tax holidays, the availability of MAT credit provides future relief. Companies must evaluate the impact of MAT on their overall tax strategy and decide whether to remain under the regular provisions or opt for lower tax regimes that exclude MAT. Compliance and strategic planning are key to managing MAT efficiently.
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