com/mu
The Honourable Pravind K. Jugnauth, Vice-Prime Minister, Instead, and against expectations, it appears that Government did
Minister of Finance and Economic Development, came up with have reasonable fiscal buoyancy as the revenue shortfall of
a set of disappointing proposals in his 2011 budget speech. Rs3.8bn was due to reductions in dividends and EU grant monies.
The Minister talked of productivity challenges, that the time had We also expected a much more elaborate discussion on the deficit
come ‘to cut the links with a social policy framework that was options and strategies for the medium term. These issues were
excessively centred on giving and spending’, and that we should unfortunately not addressed.
focus on empowerment and social integration.
integration
So instead of less Government, measured through a lower deficit,
The measures announced, in our view, fell well short of these it looks like we will get more of the same.
ambitious statements.
Next on the social policy framework, we heard of a vast number of
Driving productivity at the national level is about Government schemes, new bodies, special tax exemptions, all of which will
spending
di less
l anddbborrowing
i lless. Wh
Whatt was d done about
b t th
the probably
b bl require
i yett more civil
i il servants
t tto administer
d i i t andd control.
t l
deficit? The budget speech had a strong political undertone with monies
being paid out to various categories of citizens depending on a mix
With GDP growth rates of 4.1% in 2010 and 4.2% expected for of seemingly complex conditions. We are at a loss as to how we
2011, clearly the envy of many countries, we feel that the shall be moving away from that ‘social policy framework that was
Minister had ample room for manoeuvre to act on the deficit. excessively centred on giving and spending
spending’.
Instead the budget deficit is only expected to move from 4.5%
this year to 4.3% in 2011. We would have understood this level
of deficit had Government suffered from a drop in its fiscal
revenues.
On the empowerment front, the Minister has reintroduced All is however not negative. Tax on interest and the NRPT have
taxation on dividends, a tax that was removed in the early 90’s. been abolished and new homeowners will get an additional
Th rate
The t shall
h ll be
b att 10%.
% Taxing
T i dividends
di id d iis, iin our view,
i a i t
interestt exemption
ti on acquisition
i iti off a new h
home.
highly retrograde measure as income is effectively taxed twice
and is a clear disincentive to entrepreneurs and investors. More Further, we have for years lobbied for refunds from
contradictory, the Minister removed taxation on interest as ‘it Government (including the MRA) to be interest bearing. The
was a tax that weighed too heavily on our elders’ and yet is Minister did not give much detail but announced measures to
penalising those very elders that took higher risks and invested ensure that henceforth Government would pay its dues on time,
in private and public companies! The impact of this tax on the and that delayed payments would be subject to interest – we
flight of capital to safer shores should not be underestimated. shall see!
Moreover, all gains from sales of land and immovable property In conclusion, we believe the Minister should have shown much
5 , except
shall be taxable at 15%, p if the development
p is in the name more fiscal discipline and gone for a deficit of around 3.75%.
of an individual, in which case the rate will be 10%. Taxation of dividends is a definite ‘no go area’ and we can only
be extremely concerned as to measures in this area in future
It is clear that we shall be moving back to a world where tax years.
planning was a serious activity for many people. Again, at PwC,
we believe that the way forward is through simplification of our
i
income tax
t llaws as thi
this iimproves collection
ll ti and d compliance.
li
The Honorable Vice-Prime Minister, Minister of Finance and Economic Development has, for his first budget, announced a series
of measures aimed at three aspects: rebalancing growth, promoting productivity and enhancing social justice.
From a fiscal perspective, the proposed amendment to the law to allow companies holding a Category 1 Global Business Licence, to
carry out operations inside Mauritius is welcome. Mauritius, as a financial centre, has often been criticised as being a tax haven and
h over the
has, h years, ffaced
d tough
h challenges
h ll ffrom fforeign
i tax authorities;
h i i India
di iis an obvious
b i example.
l Theh ring-fencing
i f i off the
h
activities of an onshore company and an offshore company has not helped to defend our position. This change in policy would
provide a much needed boost to the sector at a time when substance is becoming an increasingly critical issue for the taxman. This
would allow for more activities to be undertaken in Mauritius, thereby demonstrating more commercial presence and substance.
The Minister has also called for the application of interest payments on late refunds of corporate income tax by the Mauritius
Revenue Authority (“MRA”). Save for PAYE and VAT refund, no interest is paid by the MRA on late refunds. We have, for many
years, campaigned for this to be legislated and we are pleased that this measure will restore some element of fairness in the tax
collection process.
Solidarity taxes have now become a common feature of the National Budget and, yet again, the Minister has
appealed to those who can afford to contribute more. The extension of the application of the Special Levy on
banks and the Solidarity Levy on telephony companies are such examples. The Minister has gone even
further and introduced a new levy on the Segment A banking activities to compel the banks to contribute
more. The Solidarityy Tax has also been extended to individuals,, wherebyy a person
p with a total income
exceeding Rs2m will pay a solidarity tax of 10% on his exempt income. This effectively means the
introduction of a tax on dividend income for individuals; however, dividends would still be exempt in the
hand of a recipient company. It is an agreed fact that the taxing of dividend is economic double taxation and
most modern tax jurisdictions are moving away from such a concept. Further, at a time where the
Government is seeking to stimulate SMEs, entrepreneurship and owner-managed businesses, such a tax
would be detrimental.
The Minister also introduced a new 10% tax on individuals in respect of any gains (exceeding Rs2m) derived
on sale of land and immoveable properties. In many instances, such gains made by an individual were
previously deemed to capital in nature and therefore not subject to tax in Mauritius. In essence, this 10% tax
represents nothing but the introduction of capital gains tax in Mauritius.
Mauritius
Amidst these new taxes, the Minister has also provided for some relaxation in taxes, with the abolition of the
National Residential Property Tax (“NRPT”) and the exemption of interest income with retrospective effect
from 1 January 2010. However, the removal of these taxes represents mere promises which the Minister
provided during
p g his electoral campaign
p g and much of the rebalancing g has been achieved through g the
introduction of new taxes or so-called solidarity taxes to promote social justice. Overall, the fiscal burden is
targeted at the profitable companies and the high income earners, with the objective to take from the “haves”
to give to the “have not”.
Public spending in 2011 is expected to amount to Rs84.0bn, representing a 10.2% increase over 2010 expenses of Rs76.3bn.
Public sector borrowing is estimated at around Rs180.4bn (60.7% of GDP) in 2010, up from Rs168.1bn (60.0% of GDP) in 2009.
The forecasts show a further surge in public borrowing to Rs214.5bn (a record 61.1% of GDP) in 2012. This reflects the effects of
increased Government spending in 2011 and 2012.
2012 Borrowing as a percentage of GDP is then expected to decline in 2013.
2013
Agro-Industry
Banking, Financial Services & Offshore
Employment & Social Measures
Energy & Sustainable Development
ICT
Hospitality,
l Tourism & Leisure
Manufacturing
Public Infrastructure
Real Estate
SMEs
• The measures announced under the ERCP in August are being • Recommendations in view of enhancing the viability of sugar
implemented, including the decision to reduce the Global Cess producers will be implemented through amendments brought to
the Sugar Insurance Fund Act
• Small planters, relying on sugar income only, will benefit from
the reintroduction of the tax exemption on the first 60 tonnes • The 80% advance scheme applicable to the 2010 sugar crop will
off sugar. No submission
b i i off iincome tax return will
ill b
be required
i d l apply
also l to the
h 2011 crop
• Abolition of the 15% income tax on the surplus generated from • Appropriate measures will be taken to ensure that the VAT
sugar operations by Cooperative Credit Societies (CCS) benefits currently provided to medium and large exporters of
sugar will also be available to small planters
• Loans up p to Rs25,000
5 g
given byy CCS to their members will
attract a concessionary fixed fee of Rs200 on registration and • The duty-free facility will be re-introduced on all types of double
inscription of the documents cab vehicles (4x4) for eligible small planters, farmers,
fishermen’s cooperative societies and qualified SMEs
• Rs310m will be provided for the Field Operations, Re-
grouping and Irrigation project to cover another 1,300 • A National Agricultural Biotechnology Institute will be set up in
h t
hectares off lland
d iin 2011 d tto enable
order bl th
the non agricultural
i lt l sector
t tto ffully
ll bbenefit
fit ffrom
the high tech development in the domains of agriculture, agro-
• Rs15m will be provided to maintain the incentives regarding industry and fisheries
the Fair Trade Initiative. By 2012, small and medium planters
will get the benefit of some 40,000 tonnes • Rs15m is being provided for the Multipurpose Containment
ac y to
Facility o eensure
su e b
bio-security
o secu y
• The price of molasses sold for producing potable alcohol will
be increased by Rs10 per litre of absolute alcohol representing • Two hydroponics villages will be set up as pilot projects for small
an additional revenue of Rs300 per tonne of sugar for every planters in the non-sugar sector to modernise their activities
planter
• Rs105m will be provided (which is twice the amount disbursed
in 2010) to accelerate the Food Security project.
project Some 11
projects will be supported
Going over the National Budget – November 2010 Back to Contents
PwC 10
Banking Financial Services and Offshore
Banking,
• The potential merger of the Bank of Mauritius and Financial • Any surplus generated by the activities of the Financial
Services Commission (FSC) into one single regulatory Services Commission will be transferred into the Consolidated
institution Fund
• To associate the economic development with social justice, the • The Governments introduces the housing with good living in
Budget was focused on three values namely compassion, five different schemes and increases the threshold of income
kindness and generosity. A special attention was also given to to benefit from exemption of exam fees
the most vulnerable group of the population
• Alternatives to Social Aid are also available and include both
• Rs11.6bn
b hhave bbeen allocated
ll d ffor the
h modernisation
d i i off i i and
existing d new programmes at the h NEF. The h programmes
learning tools, of which Rs215m will be invested next year to may be sponsored and are estimated at Rs5bn for the next 10
upgrade primary schools, Rs678m in secondary schools, years, including:
Rs870m to tertiary education and Rs670m to other ministries
for running programmes such as free transport for students - Training programmes to enhance employability,
including life skills training;
• Rs8bn have been assigned to the upgrading of hospitals
(Victoria, Flacq, Triolet, Agalega, etc), conducting feasibility - Provision of crèche facilities and after school care to
studies for children’s hospital, patients with mental problems, release parents, especially mothers to undertake income
and national health laboratory generating activities;
- Additional work on the landfill site at Mare Chicose • 43 other projects will be implemented under the SCP to
increase resource efficiency, improve energy consumption
- Construction of a hazardous waste facility at La patterns, and increase the supply and use of sustainable
Chaumière products and services
- A new ttransfer
f station
t ti att L
La Chaumière
Ch iè tot replace
l th
the one • Energy standards and efficiency labeling for domestic
at St Martin appliances will be enforced and the tax framework will be
• The Plaines Wilhems Sewerage Project (benefiting some reviewed to promote the use of more energy efficient
65,000 more inhabitants) will proceed, and a further Rs1.3bn appliances
es ed next
invested e yea
year in wastewater
as e a e se
services
ces • The Government will also develop a “Sustainable
Sustainable Public
• Three major sewerage projects in the regions of Grand Baie, Procurement” policy in collaboration with the United Nations
the West Coast and Pailles Guibies Environment Programme and carry out energy audits in seven
buildings
• Sewer reticulation and house connections in Port Louis and
Plaines Wilhems
• The scheme for the Solar Water Heater grant is being • The MID levy on each litre of petroleum products and each kg
reinstated at Rs10,000 per household and reinforced with the of coal and LPG will be increased to 30 cents
collaboration
ll b i off commercial
i lb
banks
k
g
• The sustainable use of marine resources is encouraged,
through new schemes to assist with the semi industrial
exploitation of our off lagoon resources. A grant scheme of
25% on the purchase of semi industrial boats is introduced,
with a budget of Rs72m earmarked for the scheme to cover all
compliant boats currently on order
• Thee fiscal
sca system
sys e around
a ou d motor
o o vehicles
e c es will cchange
a ge a
and
d be
aligned with CO2 emissions and an underlying study will be
carried out by the IMF, which should report thereon around
March 2011
• Introduction of e-Government across several ministries and departments to increase competitiveness and productivity
• Upgrade of existing computerised systems to make them more efficient and user-friendly
• Increase in the use of on-line submission and e-payment facilities across all government services
• Computerisation of the functionalities and processes of the Mauritius Police Service to connect to the Judiciary, Office of DPP
and the Prisons Service
Projects which were announced in previous Budgets but which are yet to be implemented or are still in
progress include:
i l d
• Airport infrastructure, including the extension of the terminal capacity, investment to accommodate
wide-bodied aircrafts, airport emergency runway and resurfacing of the existing runway (Rs. 11.1bn)
• p
Expansion of the Container Terminal at the Port (Rs3.5bn)
35
• Road decongestion measures such as construction of the Harbour Bridge, the Ring Road, the Terre
Rouge-Verdun-Ebène link road and the Bus rapid Transit System
• The upgrade of primary and secondary schools (Rs1bn), as well as the construction of a number of pre-primary schools
• Rs8bn investments in the health sector, including the completion of the New Jeetoo Hospital, the upgrading of hospitals, more
capacity for surgery at Victoria Hospital
Hospital, new blocks at Flacq Hospital,
Hospital a specialised hospital for the elderly
elderly, more infrastructure
capacity at the Bharati Eye Hospital, a new medi-clinic at Triolet and a maternity unit in the area health centre in Agalega
• Rs7bn expenditure over 2011 for the enhancement of law and order, including the purchase of an Offshore Patrol Vessel
(Rs1.7bn), upgrading of existing Police infrastructures, construction of a new regional detention centre at Piton, a high-security
prison for 775 detainees at Melrose, a new fire station at Tamarin and the acquisition
p q of one fire engine
g with an aerial platform
p
• Various other infrastructural projects for the welfare of children such as a shelter at Cap Malheureux and a residential drop-in
centre for development and protection of children
The Government has also announced the merger of the Central Water Authority, the Irrigation Authority, the Water Resources Unit
and the Wastewater Authority into one single Water Authority in order to improve the efficiency of water management in the
country.
Other measures announced and in line with the “Maurice Ile durable” effort include:
• Replacement of old and defective pipes (Rs454m), upgrade of the pipe treatment plant at Pailles (Rs245m), drilling of new
boreholes and upgrading of existing dams (Rs53m)
• Some Rs27bn worth of projects (Rs3bn in 2011) for the management of solid waste, wastewater and drainage systems.
Government will invest some Rs1.3 bn next year in wastewater services.
To facilitate land development, the Minister of Finance is Tax will also be introduced on all profits derived from property
introducing the Land Productivity Enhancement Scheme transactions, 15% for companies and 10% for individuals (a
(LPES) and reviewing procedures with regards to land Rs2m exemption threshold applying to the latter category).
conversion. The LPES will provide a matching platform between
the p
promoters and the market,, while facilitating
g land use. The Other tax measures will include:
scheme will however not be available for residential • Sociétés involved in real estate business will be taxed in
morcellement developments, except for mixed commercial their own name at 15%;
developments.
• The surcharge of 5% on Land Transfer Tax introduced in
The review of procedures includes: 2008 will be removed;
• A clarification of the requirements relating to permits; • New industrial leases on Pas Géométriques will allow the
• An application for a transfer of conversion rights to another offset of rental paid under the old lease against rental under
site may also be made for a change in use; the new lease;
• Conversion
C i rights
i ht may b
be ttransferred
f d tto unrelated
l t d parties
ti • No registration duty will be payable for first time buyers of
subject to a fee; a house or bare residential land subject to certain
conditions.
• Conversion rights may be transferable within a group of
companies and between ascendants and descendants/ co-
e s;
heirs;
• 100% duty free facilities will be re-introduced on all types of • The ERCP will:
double cab vehicles for qualifying SMEs
- provide guarantees to allow SMEs to raise working
• Rs600m will be mobilized through the Manufacturing and capital;
Services Development and competitiveness (MSDC) to
support SMEs; off which,
hi h Rs150m will
ill b
be used
d to ffacilitate
ili - finance SMEs through factoring; and
access to finance - provide guarantees on import loans of SMEs.
• The DBM will be transformed into a Development Finance • Use of the circular migration program with France as an
Agency (DFA) to support SMEs incubator to SMEs
• The DFA will provide lending facilities to qualified clients of • Government will seek international assistance to draw up a
amounts up to Rs5m plan for banks willing to engage in the SME segment
• The DFA will offer partial risk guarantees to commercial • The SME Partnership Fund will be revisited to introduce
banks to ensure lending to SMEs instruments for the deleveraging of SME
• The DFA will provide technical support to SMEs • A new Private Equity Fund will be created in order to develop
• A new coordinated institutional framework will be set up to financing instruments for SMEs
bring under one umbrella the Small and Medium Enterprises
Development Authority, National Pay Competitiveness
Council, National Institute for Cooperatives
Enterpreneurship, National Women Enterpreneurs Council
and Enterprise Mauritius
Personal Taxation
C
Corporate
t TTaxation
ti
VAT
Other
Comparative Tax Tables
• Individual taxpayers who are not subject to the Solidarity • Sociétés in real estate business will be taxed in their own
Income Tax, and whose children, up to a maximum of three, name instead of the individual partners at the rate of 15 %
are following a non-sponsored full-time undergraduate course
at a recognized tertiary education institution will be allowed • The amount of income tax exemption for lump-sum on
Rs80,000 per child for courses followed in Mauritius and retirement and severance is increased from Rs1m to Rs 1.5m
Rs125,000 per child
h ld ffollowing
ll courses overseas. The
h ffiscall • The due date for payment of income tax by an individual
support will be available for 3 consecutive years of study taxpayer who submits his annual income tax return and
• The National Residential Property Tax is abolished with effect effects payment of tax electronically is extended by 15 days
from 1 January 2010
• The Cooperative Credit Societies will be exempted from tax on • The special solidarity levy applicable to providers of fixed and
the surplus generated from sugar operations mobile telephony services will be maintained for the next two
financial years. Thus, the levy will be payable for the two years
• The amount of capital allowances that can be claimed on of assessment commencing on 1 January 2011 and 2012 at the
motor cars is limited to Rs3m per motor car rates of 5% on book profit and 1.5% on turnover of the
preceding year
• From 1st March, wheat flour and bran, edible oils, margarine, sterilised liquid milk,
curdled milk and cream and yoghurt, live chickens and chicks, animal feed and
fertilizers will be moved from zero-rated to exempt supplies. Producers of such
goods will be able to recover input tax when they export
• The license fees payable in respect of liquor and alcoholic products under the Excise Act will be doubled
• Rates of excise duty will be increased on rum and liquor by Rs100 per litre
• The rate of excise duty for all other alcoholic products will be raised by 20%
• The rate of excise duty on cigarettes and tobacco products will be raised by 25%
• The specific rates of excise duty on petroleum products which have remained unchanged since 2002 are increased by 10%
• An adult first-time buyer of a house or bare residential land will not bear registration duty if his total annual income is below
Rs2m. This benefit will apply on the first Rs1.5m of the price of a house, or the first Rs750,000 of the price of bare land provided
the beneficiary begins construction within one year and completes within three
• The threshold for exemption from land conversion tax for the small and medium planters will be raised from one to two hectares
on certain conditions. Planters regrouping their land assets will benefit from their individual tax exemptions
• Following the introduction of the taxes on profits and gains on sale of land, the surcharge of 5% on land transfer tax introduced
in 2008 will be removed
• When a lessee of an industrial lease on Pas Géométriques and State Land opts for a new lease at market value any rental paid in
advance under the old lease will be allowed to be offset against the increased rental under the new lease for the same period
• The system of motor vehicle taxation will be changed to fully reflect the polluter pay principle and to be based on a CO2 emission
standard
• The rate of excise duty on PET bottles, plastic bags and cans is doubled from Re1 to Rs2
• License fees of casinos and Gaming Houses ‘A’ are increased from Rs500,000 to Rs3.5m
• License fees of all other betting outlets, including totalisators, football betting outlets and bookmakers
operating through remote control communications are increased by 100%
• License fees of sweepstake organizers, local pool promoters, agents of foreign pool and operators of dart
games are increased by 50%
• The pool betting duty on foreign football matches is raised from 10% to 12%
• The rate of tax on fixed odds betting on football matches and horse racing is raised from 8% to 10%
Note:
N1 The tax year has been aligned with the calendar year, covering January to December
A six month tax year for July 2009 to December 2009 had been introduced to align the tax year with the calendar year. The income taxes due for this period were settled by
N2
5 April 2010
Note:
N5 Applies to individuals with total income including exempt income of more than Rs2m
N6 This will not apply to gain on properties received by way of inheritance or transferred by the parents to their heirs. Moreover, the first Rs2m of gains will be exempt.
Note:
N1 The tax year has been aligned with the calendar year, covering January to December;
A six month tax year for July 2009 to December 2009 had been introduced to align the tax year with the calendar year. The income taxes due for this period were
N2
settled by 5 April 2010. An individual is entitled to only 7/13 of the Income Exemption Threshold;
N3 Category A refers to an individual who, in an income year , does not have any dependent;
N4 Category B refers to an individual who, in an income year, has one dependent only;
N7 Category E refers to a retired person who, in an income year, does not have any dependent;
N8 Category F refers to a retired person who, in an income year, has one dependent only.
Note:
N1 An additional deduction of Rs 70,000 is available if a person, his spouse or dependent child is handicapped;
Annual
Capital Allowances – Year of Assessment 2012
Allowance
Plant & machinery 35%
Hotels 30%
Computer and electronic equipment 50%
Commercial premises including shops and shopping malls, offices, showrooms, restaurants and other entertainment places
5%
and clinics
Motor Vehicles (Maximum Rs3m of allowances per vehicle) 25%
Equipment and machinery costing less or equal to Rs 30,000 100%
Tax Deduction at Source Rate of tax Rate of tax Rate of tax Rate of tax Rate of tax
Year of Assessment 2012 2011 2010 2009/2010 2008/2009
Royalties 15% 15% 10% 10% 10%
Rent 5% 5% 5% 5% 5%
Payments to contractors and sub-contractors 0.75% 0.75% 0.75% 0.75% 0.75%
Payments to providers of services 3% 3% 3% 3% 3%
Note:
N1 The tax year which previously ran from 1 July to 30 June has been aligned with the calendar year.
N2 These companies are liable to tax at an effective rate not exceeding 3% on their foreign source income.
N3 The rate of Alternative Minimum Tax (AMT) is 7.5% as from YOA 2007/2008 (previously 5%).
30% of investment spread equally over 3 years from the year of investment limited to Rs 300,000 per annum. Special tax credit up to 60% of equity will be
N4
available over a period of 6 years in respect of investment in spinning, dyeing and weaving companies. Not available to tax incentive companies.
N5 10% of investment spread in any proportion over 3 years from the year of investment. Not available to tax incentive companies.
N6 Depending upon their volume of their export sales, companies may obtain a tax credit of up to 40%.
N7 Credits under Sections 69, 70 and 71 are limited in such manner as not to reduce the tax payable to less than 15% of chargeable income.
N8 The lesser of foreign tax paid and Mauritius tax attributable to foreign income.
N9 These companies are liable to tax at an effective rate not exceeding 3% (previously 5%) on their foreign source income.
N10 Special tax credit of 60% of equity of these companies available to the subscribing company.
N11 No tax credits and tax holidays will be available as from year of assessment 2007/08 except to existing beneficiaries.
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Going over the National Budget – November 2010 Back to Contents
PwC 38
Creating value through our services
Tax (2 of 2)
Investigations
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e dp
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o o aa and d informal
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ee gs
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Risk Advisory helps management, the board and third parties enhance and
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We work k closely
l l with h clients
l and
d our services are d
designed
d to h
help
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h reach
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We help p clients identifyy and focus attention on the factors in business that are critical to
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Going over the National Budget – November 2010 Back to Contents
PwC 42
Creating value through our services
Deals
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review
Where businesses For companies, their Are you experiencing We assist Where a business is
are underperforming, lenders, shareholders one or more of the organisations that facing financial
in distress or in crisis, or other stakeholders potential issues with need to reduce distress or
we provide tailored in businesses facing your business? operating costs and insolvency, we may
business review financial under- achieve a simplified be able to help save
services either for performance or crisis, • Squeeze on more transparent it if action is taken
financial stakeholders we deliver working
g capital
p corporate structure early enough
enough.
or for the business restructuring by dissolving inactive Alternatively, we can
• Unexpected
itself. These services solutions and help companies that have help financial
collapse of
clarify the situation build a platform for fulfilled their stakeholders to
profitability
for both parties and recovery. economic purpose. recover value in an
allow clearer • Unsustainable insolvency.
evaluation
l ti off theth running costs
available options.
• Forecast covenant
breach of loan
More information on agreement
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