Strides Pharma Science Limited Demerger
The National Company Law Tribunal (NCLT), Mumbai Bench, approved the Scheme of Arrangement between Strides Pharma Science Limited (“Strides”), Steriscience Specialities Private Limited, and Onesource Specialty Pharma Limited (“Onesource”) on November 14, 2024. This scheme facilitates the demerger of certain business units from Strides and Steriscience into Onesource.
Highlights of the Demerger
Business Realignment:
- The Identified CDMO Business and Soft Gelatin Business of Strides will transition to Onesource.
- The Identified CDMO Business of Steriscience will also be demerged into Onesource.
Record Date:
December 6, 2024, has been designated as the date for determining Strides shareholders eligible to receive Onesource equity shares.Share Allocation:
Onesource will issue 1 fully paid-up equity share (face value Rs. 1) for every 2 fully paid-up equity shares (face value Rs. 10) held in Strides as of the Record Date.
Cost of Acquisition and Tax Considerations
Cost of Acquisition (COA):
Post-demerger, the COA for equity shares of Strides and Onesource will be allocated as follows:- Strides Pharma Science Limited: 89.35%
- Onesource Specialty Pharma Limited: 10.65%
Example: A shareholder holding 60 shares of Strides (at Rs. 1,000 per share) will receive 30 shares of Onesource. The COA will be:
- Strides (60 shares): Rs. 53,610 (Rs. 893.50 per share)
- Onesource (30 shares): Rs. 6,390 (Rs. 213 per share)
Tax Implications:
- The issuance of Onesource shares to Strides shareholders under Section 47(vi)(d) of the Income Tax Act is not treated as a taxable transfer.
- For capital gains purposes, the date of acquisition of Onesource shares will align with the original acquisition date of the corresponding Strides shares (as per clause g of Explanation 1 to Section 2(42A) of the Act).
Disclaimer
This summary is intended for general informational purposes only and does not replace professional legal, tax, or financial advice. Strides and Onesource are not liable for the information provided, and changes in laws or regulations may require further review. Shareholders are encouraged to consult their advisors for specific guidance.
