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054

Case 054Fund economics, NAV and LP decisionsWarm up

The Nirvara Cat III AIF earns 18% before tax. At an illustrative 30% effective tax paid inside the fund, against 15% paid by investors on their own gains, how different are the net returns, and why do Indian long-short managers care so much about structure?

1The situation

Nirvara Capital runs a long-short equity strategy as a Category III Alternative Investment Fund. After fees, the portfolio earns 18% a year before tax.

For illustration only, assume the fund pays tax on its income at an effective 30%, and that an alternative structure would let the same gains flow through to investors, who would each pay an effective 15% on their own gains. A family office is weighing a Rs 1 crore investment held for five years. These rates are illustrative; actual tax depends on the structure, the nature of the income and the current law.

2Your task

What does each structure deliver after tax, in a year and over five years, what extra pre-tax return would the fund-level structure need to match, and what should the reader check before relying on any of it?

Quick check

At these illustrative rates, how many points of the 18% does tax take under each structure?

Worked solution

Try it on paper, then open one step at a time.

30-second answerThe answer to give first

At these illustrative rates the investor nets 12.6% a year when tax is paid inside the fund and 15.3% when it is paid in their own hands. Tax takes 5.4 points against 2.7. Over five years Rs 1 crore grows to about Rs 1.81 crore against Rs 2.04 crore, and the fund-level structure would need 21.9% before tax to keep up. Confirm current tax rules before using any figure here.

Step 1Why does it matter who pays the tax?

Because the rate depends on who the taxpayer is. Think of two salaried friends earning the same amount, one paid through a company that pays a flat high rate before handing over the rest, the other paid directly and taxed on their own slab. Same income, different take-home. Under the fund-level assumption Nirvara pays 30% of 18%, so 5.4 points go before the investor sees anything; if gains flowed through and the investor paid 15%, only 2.7 points would go. In India, Category I and II funds have generally been treated as pass-throughA tax treatment in which the fund itself is not taxed on certain income; the income is taxed in the investors hands as if they had earned it directly. for most income while Category III funds have generally been taxed at the fund level, which is why the question comes up. Confirm the current rules before relying on either statement.

The same 18% before tax, two ways of being taxed (illustrative rates)Tax paid inside the fund, 30%12.6% to you-5.4Tax paid by the investor, 15%15.3% to you-2.718% before tax0%To net 15.3% after a 30% fund-level tax, the fund must earn 21.9% before tax: 3.9 more points of return
At illustrative rates, an 18% pre-tax return becomes 12.6% when tax is paid inside the fund at 30% and 15.3% when the investor pays 15% on their own gains, and the fund would need 21.9% before tax to match.
Step 2What does the gap do to Rs 1 crore over five years?

Compound each net rate. Rs 1 crore at 12.6% a year becomes Rs 1.810 crore in five years; at 15.3% it becomes Rs 2.038 crore, about Rs 23 lakh more for the same portfolio. If the investor-level tax is paid only once, at exit, rather than every year, the untaxed gains keep compounding in the meantime and the figure rises to about Rs 2.095 crore. That deferral is worth something on its own and is easy to forget.

Rs 1 crore, five yearsNet a yearValue, Rs croreTax cost, Rs lakh
No tax at all18.0%2.2880
Tax inside the fund at 30%, every year12.6%1.81048
Investor pays 15%, every year15.3%2.03825
Investor pays 15%, once at exit15.9%2.09519
At illustrative rates, Rs 1 crore earning 18% before tax ends five years at Rs 1.81 crore under fund-level tax and Rs 2.04 crore to Rs 2.09 crore when the investor pays, depending on whether tax is paid yearly or at exit.
Step 3How much harder must the manager work to make up the difference?
The relationship
rpre=15.3%1−0.30=21.9%r_{pre} = \frac{15.3\%}{1 - 0.30} = 21.9\%
15.3%what the investor nets under the investor-level structure
0.30the illustrative fund-level tax rate
21.9%pre-tax return the fund-level structure needs to match
What it says in wordsTo hand the investor the same 15.3%, a fund taxed at 30% must earn 21.9% before tax, 3.9 points more than the 18% it actually makes.

That is the real reason managers care. 3.9 extra points of pre-tax return a year is more than many long-short funds earn in alpha, so the wrong structure can erase the skill the investor is paying for. It also explains why allocators compare funds on post-tax returns to them, not on the gross number in a factsheet, and why some Indian managers run offshore or differently categorised vehicles alongside the Cat III fund. Rates, categories and treatment of different kinds of income change; confirm the current position with a tax adviser before any decision.

Where candidates lose it

The usual slip is subtracting the tax rates from the return, 18 less 30 or 18 less 15, instead of applying them as a share of it. Tax takes 30% of the 18, not 30 points.

The second is quoting a current tax rate from memory as fact. The interviewer wants the framework and the arithmetic, then a clear statement that the reader must check the law in force, because rates and categories do change.

What the interviewer asks next

  • Management and performance fees are charged before the 18%. Does fund-level tax apply before or after them, and why does it matter?
  • Half of Nirvara's return is short-term trading gains and half long-term. How would that split change the comparison?
  • An allocator sees 18% gross in two funds with different structures. How should the factsheet comparison be done?
← Case 053Ushvin Industries, worth Rs 10,000 crore, will spin off Ushvin Chemicals, with EBITDA of Rs 300 crore against peers at 12x. Index funds holding the parent must sell the new shares. How do you trade the spin-off?Case 055 →Design a financial stress index for five economies, Aldora, Brevia, Corvin, Dessala and Estmar, from credit growth, the current account balance and short-term external debt to reserves. How do you normalise, weight and rank, and what are the index's weaknesses?

Company names and figures are illustrative.

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