Fullerton Acquisition Deal: Sumitomo Mitsui Group Faces $670-mn Tax Bill

Sumitomo Mitsui Financial Group is facing a $670-million tax bill from India on its $2-billion acquisition of Fullerton India Credit, far outweighing what the Japanese lender has set aside, according to people familiar with the matter.

The South Asian government’s tax department has asked the bank to pay the amount on behalf of seller Fullerton Financial Holdings Pte, arguing that it should have withheld the sum during the acquisition, the people said, asking not to be named as the information isn’t public.

Sumitomo Mitsui held back only $170 million for the deal, whi­ch compl­e­ted last year, taking its addi­tional tax liability to $500 million, they said.

The demand was made in late November, one of the people said. The demand to SMFG comes after India ended multiyear tax spats with global companies from Cairn Energy Plc to Vodafone Group Plc, that were tarnishing the nation’s image as a business-friendly destination.

The Centre scrapped a nine-year rule on retroactive taxes in 2021, that triggered tax demands of billions of dollars.

The sudden request leaves Sumitomo Mitsui facing much higher costs than initially anticipated. Japan’s second-largest lender is working with India’s government and Fullerton to find a solution, the people said. Fullerton Financial is a unit of Singa­pore’s state-owned investor Tem­asek Hold­ings Pte and owns the remaining 25 per cent of Fullerton In­dia, according to its website.

Faced with weak growth prospects at home, Sum­itomo Mit­sui has been allocating resources to Asia’s emerging markets in recent years and acqu­ired a 74.9% stake in Fullerton India last year, marking the first entry into the country’s retail financial business by a Japanese bank.

A spokesperson for Sumitomo Mitsui declined to comment on the specific transaction and said the lender is “taking actions that comply with local laws and regulations and will continue to take appropriate measures” based on these.

A spokesman for India’s finance ministry didn’t resp­ond to an email and calls seeking comment.