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Mid-Year Convention Under a Know-How Valuation: XYZ Ltd

The same royalty stream, the same rate, the same five years — INR 180.65 crore or INR 168.46 crore depending only on when in each year the cash is assumed to arrive.

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Topic
IBC Insolvency
Published
September 7, 2026
Last updated
Sep 24, 2026
Reading time
4 min
0:00
Last updated: September 2026Verified against: Government sources

The assignment

Abhishek is engaged by XYZ Ltd to value Know-How — specifically, one know-how on how to produce a special asset for the use of handicapped persons, on which the major work of the XYZ ltd. depends. The company is in the process of a merger deal.

InputValue
Life of know-how5 years
Revenue in current year400 Cr.
Royalty rate in similar assets in the industry10%
Growth rate in revenue expected20%
Income tax rate26%
Weighted average cost of capital12%
Weighted average rate of return on intangible assets15%

Mid-year convention

Particulars0.51.52.53.54.5
Revenue (growth @ 20%)480576691.2829.44995.33
Royalty rate @ 10%4857.669.1282.9499.53
Taxes @ 26%12.4814.9817.9721.5725.88
Post-tax royalty35.5242.6251.1561.3873.65
Present value @ 15%33.1234.5636.0737.6339.27

Fair value without TAB: 180.65.

End-year convention

Particulars12345
Post-tax royalty35.5242.6251.1561.3873.65
Present value @ 15%30.8932.2333.6335.0936.62

Fair value without TAB: 168.46.

What the mid-year convention assumes, and when it is right

The cash flows are identical in both tables — 35.52, 42.62, 51.15, 61.38, 73.65. Only the discount periods change: 0.5 to 4.5 against 1 to 5.

The end-year convention assumes every year's cash arrives on the last day of the year. That is almost never true. Royalties, sales and margins accrue throughout the period, so the average rupee arrives around the middle — which is what the mid-year convention models.

The effect is a uniform uplift of half a year's discounting: at 15 per cent, roughly 7.2 per cent on every present value. Here that is 12.19 crore of a 168 crore valuation.

Which is correct depends on the facts. A business with continuous revenue supports the mid-year convention. An asset paying a single annual royalty on a fixed date does not — its cash genuinely arrives once, and the convention should match the payment terms.

Note the other choice this illustration makes, which is at least as important. The discount rate is 15%, the weighted average return on intangible assets, not the 12% WACC. The Standard's rule is that the company rate is a starting point with suitable adjustments to consider the risk etc. of the intangible assets in comparison with the company as a whole — here, a 300 basis point premium. Using 12% instead would have raised the answer by around 8 per cent.

Why the tax is deducted before discounting

The royalty saving reduces a deductible expense, so the benefit is net of tax. At a 26 per cent rate, a royalty of 48 produces a saving of 35.52 — and discounting the gross 48 at a post-tax rate would overstate the value by the whole tax charge.

Common mistakes

  • Applying the mid-year convention where royalties are paid on a single annual date.
  • Using the WACC rather than a rate adjusted for the intangible's risk.
  • Discounting pre-tax royalty savings.
  • Presenting a value without stating which convention was used.
Quick recapKey facts & short answers

Key Facts About Mid-Year Convention

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What were the inputs?

Life of the know-how 5 years; revenue in the current year INR 400 crore; royalty rate in similar assets in the industry 10%; expected growth in revenue 20%; income tax rate 26%; weighted average cost of capital 12%; and weighted average rate of return on intangible assets 15%.

Which discount rate was used?

15% — the weighted average rate of return on intangible assets, not the 12% weighted average cost of capital, because the intangible carries more risk than the company as a whole.

Mid-Year Convention: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

Related Services & Guides

Why This Matters

Staying compliant with Indian regulations protects your business from penalties, interest and unnecessary legal trouble. It is always wise to maintain proper records and documentation so that any future scrutiny can be handled smoothly. Rules and thresholds in ibc insolvency are revised periodically, so it helps to review your obligations at the start of each financial year.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

Life of the know-how 5 years; revenue in the current year INR 400 crore; royalty rate in similar assets in the industry 10%; expected growth in revenue 20%; income tax rate 26%; weighted average cost of capital 12%; and weighted average rate of return on intangible assets 15%.

15% — the weighted average rate of return on intangible assets, not the 12% weighted average cost of capital, because the intangible carries more risk than the company as a whole.

Revenue growing at 20% from 480 to 995.33; royalty at 10% giving 48 to 99.53; tax at 26%; post-tax royalty of 35.52, 42.62, 51.15, 61.38 and 73.65; discounted at 15% at periods 0.5 to 4.5 to 33.12, 34.56, 36.07, 37.63 and 39.27 — a fair value without TAB of 180.65.

The same post-tax royalties discounted at periods 1 to 5 give 30.89, 32.23, 33.63, 35.09 and 36.62 — a fair value without TAB of 168.46.

Because the mid-year convention assumes cash flows arise evenly through the year and so discounts them for half a year less, raising every present value.

About 12.19 crore, or roughly 7.2 per cent of the end-year figure — approximately half a year at the 15 per cent discount rate.