Beer market of Kazakhstan acquired both traits of East European countries and South Eastern Asia taking a transitional position between them by many criteria and consumption style. Yet there is a positive trend in beer production which differs Kazakhstan from most of the neighboring countries. The market has remained consolidated in the hands of two international players because of its small size. However, it faces dynamic processes such as fast growth of draft beer sales, up and downs of regional companies and Carlsberg Group’s ultimate expansion. Excessive mainstream segment has declined over the recent years, yet, Zhigulevskoe and national brands with regional links have yielded their positions to a range of new products. In our review special attention was paid to regional analysis of the markets. In 14 regions of Kazakhstan we compared the companies’ positions, the market price segmentation and DIOT channel development. Besides we have compared the beer market of Kazakhstan to neighboring countries. ...
Beer market of Russia 2018
- General market picture
- Foreign trade setting records
- Demography as challenge to branding
- Aged consumer
- Declining of youth brands
- Nostalgia on trend
- DIOT feels at home
- 5.0 Original is the new face of import
- Positions of Market Leaders
- Carlsberg Group
- AB InBev Efes
- AB InBev
Ukrainian beer market 2018
- Better than yesterday
- Performance by value
- Positions of Ukrainian brewers
The beer market dynamics in Russia is approaching zero, yet major brewers are divided into those who developed considerably in 2017 and those who considerably reduced their volumes. For instance, company Efes has managed to substantially extend their sales due to restrained pricing policy and activity in the modern trade. Heineken has also demonstrated an excellent performance promoted by significant increase of advertisement budgets launching a non-alcohol sort of the title brand and unusual activity in the economy market segment. Carlsberg and AB InBev have been focusing on margins and lost a market share of their inexpensive brands. Serious dependence on PET package and mass enthusiasm about Zhigulevskoe have negatively impacted the most of big regional brewers, that have been for the first time pressed by the leaders in the key sales channels, especially in Volga and Central regions. In the small business there has been a noticeable slowdown in appearing of new restaurant breweries, yet the number of craft breweries has been growing rapidly. In 2018, the beer market is likely to grow a little, while the share of AB InBev Efes may decrease due to the integration. ...
India. Cross-border transfers of intangible assets by foreign entities not taxable: Delhi HC
The Delhi High Court recently passed a long-awaited judgment against attempts by Indian revenue authorities to tax capital gains on cross-border transfers of intangible assets by foreign entities.
As a result of this latest clarification, only capital gains made by foreign entities on cross-border share transactions would henceforth be taxable by Indian authorities under Section 9 of the Income Tax Act.
The landmark verdict was delivered on a challenge made by Foster’s Australia to a May 2008 Authority of Advance Rulings (AAR) determination which deemed the transfer of intangible assets associated with British beer manufacturer SABMiller’s acquisition of Foster’s India over 10 years ago as taxable under Indian law.
The Indian tax authorities had supported the AAR decision on the ground that the transfer of the Foster’s brand name for use in India was taxable as it had acquired domestic licences and gained substantial value through business conducted in this country.
In contrast, Foster’s Australia relied on a strict interpretation of Section 9 of the Income Tax Act, 1961, and contended that the income arising out of a transfer of a brand name could not be taxed in India if the intellectual property rights were held by a foreign entity.
The high court eventually agreed with the Foster’s Australia submissions and contended that the permission given to SABMiller to utilise the brand name was, in fact, a mere “user right” transferred by an overseas body and not amenable to taxation in India under Section 9.
While interpreting the relevant retrospective provision, the court held that the law had created a deeming provision for taxability of capital gains made on indirect transfers of capital assets alone and would not apply to intangible assets such as brand names or logos.
In the absence of a specific provision on the issue, the court concluded that international merger and acquisition norms permitting taxation only at the proprietary location of an asset were to be followed. As such, only the parent country of the transferor would have a right to such taxation, regardless of the usage of the asset in question.
According to Ketan Dalal, senior tax partner, PricewaterhouseCoopers, the judgment was a well-reasoned one. “The fact that a brand has generated goodwill in India or was nurtured here are irrelevant for the purposes of taxation,” said Dalal. “Given the increasing importance of intangible assets and transactions of such nature, international companies will certainly get comfort that one potential hurdle in relation to such transactions seems to have been addressed. Now one only hopes that the tax department will accept this judgment and not take the matter to the Supreme Court.”
- Capital gains made by foreign entities on cross-border share transactions would be taxable
- The landmark verdict was delivered on a challenge made by Foster’s Australia to a May 2008 Authority of Advance Rulings
- The court concluded the international merger and acquisition norms permitting taxation only at the proprietary location of an asset were to be followed
- Only the parent country of the transferor would have a right to such taxation, regardless of the usage of the asset in question
28 Июл. 2016