Siemens Limited announced cost apportionment guidance for shareholders following the demerger of its Energy Business to Siemens Energy India Limited (SEIL) under a Scheme of Arrangement.
The Scheme was sanctioned by the National Company Law Tribunal (NCLT) Mumbai on 25 March 2025, with an effective date of 25 March 2025 and appointed date of 1 March 2025.
SEIL allotted 35,61,20,505 equity shares to Siemens Ltd shareholders on the record date of 7 April 2025, in a 1:1 ratio (one SEIL share of face value ₹ 2 for every one Siemens Ltd share of face value ₹ 2).
For determining post-demerger cost of acquisition, shareholders should apportion their original Siemens Ltd share cost as follows:
Siemens Limited: 76.18%
Siemens Energy India Limited: 23.82%
The allotment of SEIL shares is not considered a transfer under Section 47(vid) of the Income Tax Act. The acquisition date for SEIL shares will be the same as the original Siemens Ltd shares.
This communication provides general guidance, and shareholders are advised to consult their tax advisors for specific implications.