With Ed Dixon, Kapil Dua, and Michael Green
Compliance and adherence to thereof are one of key considerations for any entity looking to expand into the Indian Marketplace. Kapil Dua, Seamless’s Chief Executive Officer, Ed Dixon, Executive Director UK, and Michael Green, Executive Director and Senior Vice President North America, discuss exactly what needs to be done and how when establishing a footprint in India.
Kapil, Ed, and Michael highlight the current state of tax, regulatory and compliance landscape and speak of the shift taking place that opens up the country as a destination of choice for businesses wanting to extend their operations into international territories.
Three Key Takeaways
- Setting up a legal entity in a new country or marketplace requires a comprehensive understanding of the local legal and regulatory framework. From company registration and taxation to employment and intellectual property laws, it is crucial to thoroughly research and comply with all relevant regulations to ensure a smooth and compliant establishment process.
- Navigating the complexities of setting up a legal entity in a new country can be daunting. It is essential to seek expert guidance from legal professionals and consultants with expertise in the target market. Additionally, establishing strategic partnerships with local entities or professionals can provide invaluable insights, local market knowledge, and support in navigating cultural nuances and business practices.
- Careful consideration needs to be given when setting up a legal entity in a new marketplace to a business structure and strategy. Analyse market conditions, consumer behaviour, and competitive landscape to determine the most suitable legal entity type (such as a subsidiary, branch office, or joint venture) that aligns with individual expansion goals.
Below is the transcript
We’re now going to seamlessly move our way into the world of compliance. And hopefully, those of you that saw us dancing last night, underline that the compliance guys can dance, and girls. So, we’re going to try and give you a few different perspectives.
Throughout this session, we’ll try and make it a bit of a conversation, we’ll throw up a few slides because it’s compliance, but just in terms of the different perspectives you’re gonna get from us.
Kapil, who obviously founded the business, and has led the business in India will particularly focus on the kind of India experience and leading the Seamless organisation, Michael, who ran the business in India as well, but originates from the US and is now based in Washington, DC, so will give us the US perspective and myself. I moved here in 2011, to run the now Seamless organisation, and I’m based out of the UK, so you’re going to get three different perspectives.
Hopefully, if I press this, we’re going to get some slides. You’ve all heard a lot about Acumen over the last couple of days and the great work that the team is doing. There is, as you’ll have also heard, another part of the Sannam S4 Group called Seamless. We support organisations, particularly higher education organisations, but also the wider international nonprofit sector, and businesses with their work as they internationalise, in India, Asia and beyond. We focus particularly on the real kind of nuts and bolts of establishing legal entities dealing with taxation, compliance and record regulatory matters. So that’s just a little bit about us. I’m now going to turn the conversation to my colleagues. Michael, I think we’ll start with you. Maybe you can kind of help us run through I guess, the key models that we tend to support institutions with from a compliance perspective.
Thanks Ed, and welcome everybody. It’s been a wonderful couple of days here, seeing some very familiar faces and reconnecting as a group and as a team. Thanks to all of our clients who have flown from all over the world, to spend some time with us to gain some of these insights.
When you’re talking about the different operating models, there’s a number of legal structures that universities have explored, and Kapil can go into a little bit more detail about which ones are most utilised in the Indian context.You have incorporated structures, you have unincorporated structures, which is our kind of in-country representation, model driven by Acumen. I think we’ll get into it a little bit later, but there’s a whole spectrum of those that have those sorts of options, as well, that we can talk about that have various levels of risk attached to them. Third, is online delivery, something that we’ve heard about quite a bit over the last couple of days, but it’s another operating model that universities are looking at when they talk about global education and talk about delivery of education in India, then we also have collaborations with Indian higher education institutions. TNE as off the back of the NEP, is a really great opportunity that we’re seeing develop, and that has kind of matured perhaps in other parts of the world and is really starting to take hold and take shape and form here in India.
I think the last one, some of us will be travelling to GIFT City, up in Gujarat on Monday to explore this opportunity, but opening a campus. There’s been lots of discussion of this over the years but from the Seamless perspective, we’re looking at this from a very pragmatic perspective in terms of building budgets.
And back to legal structure, what types of legal structure? How would you repatriate tuition dollars, these sorts of things are what we were looking at, as that model kind of takes hold in India. So those are about the five kinds of operating models that we’ve seen within the higher ed context.
Perfect, Michael, thank you, we’re now going to get into a bit of detail. Kapil, maybe you can kick us off by looking at the legal entity options that are presented in India for institutions and I’ll take us through a few of the thought processes. We’re going to cover this at a reasonably high level, there’s a lot of detail, but over to you Kapil.
Thanks. Let me paint the picture first. So why do you need a legal entity? That’s the first question which we need to decide on as a foreign institution. Once we decide, ok, this is the reason which I’ll cover later on. But once we decide that the legal entity is needed, then India is when I use the word very easy.
In a bigger context, you have two different types of structures. One we call it as the incorporated structure. The other is the unincorporated structure. If I have to explain again in a very simple language, non-GAAP incorporated structures are again bifurcated into two basic parts. One is an extension of your foreign institution, which means a liaison office, branch office, project office and when I say it’s an extension, which means you’re opening these offices, legal entity structure in India, where your liabilities risk everything, still flow back to the institution.
Anything you do in India under say, for example, liaison office or a branch office, project office, are generally not done by the foreign institutions, because project offices are incorporated for a specific project, like building up the Delhi airport, for example, an institution will not do it. So, liaison offices, branch offices have unlimited liabilities attached to the foreign institution. That’s a very basic difference, which I will create in the first part of the incorporated structure. And, second, basic art is more about what you can or can’t do from the structure like a liaison office, you’re not allowed to receive any funds in India. So you just have a bank account. Money comes from overseas, and you spend the money. It’s a receipt and expenditure. There is no income there.
So that’s the liaison office for you. Similarly, branch offices, as we hear in the higher education institution, is like a branch of a head office sitting outside, you are allowed to receive fees. Once you open a branch, you are allowed to receive fees, but it’s taxed at a very high rate 40% plus, and like Michael was saying about the GIFT City, so I’ll come to that why, or whether branch office is a solution in India, as you are going to give Syrian may ask them, Can we open our branch there. So we’ll come to that.
The second part of the incorporated structure is again, very simply put, you have a for profit, and nonprofit. Under the for profit, you have a PLC or LLC model in the US. You have LLP, which is a limited liability partnership. In the nonprofit, you have two options, you can open a trust, which is a very well-recognised nonprofit structure anywhere in the Western world as well. And the other is a section eight company, which is a nonprofit company, you do get the benefit of tax-free perspective, you take some tax exemption from the local body and you go on for Section eight. Again, there are implications for having a for-profit and nonprofit. I’ve spent 15 years convincing the international institution boards telling them what is for profit, it takes time. It takes time for a charter document which is an 1800 century document lying somewhere and I have to search for it. It depends upon many other factors. So this is primarily from an incorporated structure perspective.
OK, fabulous. Michael, I think it’s fair to say, the US has kind of led the way on deploying legal entity structures in India, maybe you could unpack some of why?
I think when we’re engaging institutions, it’s really important that we understand what their broader vision is for their involvement in a particular market. It all goes back to the underlying objective that they have for many institutions here. Increased visibility, increased student mobility, is a core focus of their institution and there’s various different models that can support that. That’s what we’ve built with the Acumen ICR model, it’s one that can be really effective, efficient, compliantly and well managed to support that aim.
When you get to joint research, when you get to alumni giving, when you get to moving funds internationally, one way or the other, that’s typically when you get to a point where you need to start exploring a legal structure. So in the US context, with the size of the research institutions that are there with the type of faculty that they have in the types of projects that they’re working on. They’re deploying funds or looking for ways to deploy funds globally in order to further their research. I’d say research is the number one thing that tips the scales. Increasingly, we’re seeing development. A university will have off the back of generations now, student mobility, success stories of students that studied in the US came back to India, became very successful and wanted to give back to the institution, but wanted to tax credit locally, as part of that kind of gift.
Structuring that in a way where the institution’s objectives, the alumni objectives can still be accomplished, it’s kind of another thing that we’re seeing more and more, and now, this kind of third category, which is super new, with gift and then the recent UGC guidelines is opening a campus.
Obviously, if you’re going to open a campus in India, there’s going to be quite a lot of transactions between the two countries. I think those are the three main areas, I don’t know, anything else in terms of kind of major objectives of the institutions? I think there’s some
To be honest, too many. So we at Sannam S4 for the last 15 years brought five of the top 10 US institutions into India. Pretty well known Ivy League’s to the tier two beyond 100. It covers many things, we have institutions who are doing clinical trials in India, right, we are having institutions who are just writing curriculums for the Indian institutions, publishing houses and many other things. So when I go on the road in the US and North America, I do say around 12 different objectives, which an institution is trying to achieve in India, and they have successfully done almost 10, if I can put it but it’s expanding, it’s expanding.
Yeah, and I think the point on that is just back to the structuring bit is, oftentimes there’s not one structure that will service all of the objectives. So more and more institutions are needing to open up dual structures, with for profit entities with nonprofit entities in order to cover all of those objectives. Just at a very high level, one of the big no-no’s in a nonprofit entity in India, is you can’t take any money out of India, out of an Indian nonprofit. So that completely cuts off if you want to bring money out of India, you’re going to have to do it through a for profit structure.
But even to get the money into a nonprofit is also difficult. So it’s a different world altogether.
Brilliant. OK. That was the introduction. On to legal entities, there’s much more but we’ll move on Kapil. Let’s talk a bit about in-country representation. Models, obviously, the Acumen model, as Michael has outlined, absolutely a leading model in this space. But there are other models. And I think we’re just gonna dive into a little bit about what an in-country representation model is, and some of the do’s and don’ts.
Well, I don’t need to explain, we already have this beautiful audience who already know 80% of my colleagues are sitting here, even more than that. So again, if I simplify that, for some of us who don’t know what in-country representation is in an incorporated model, I have already explained the incorporated model. Which means you do not have a legal entity in India, which means you have a person on ground, who is waving a flag, who is trying to achieve your objectives.
Objectives could be for example, student recruitment, and others, the partnership, the research and many other objectives. It works in a very simple way that you have a service provider like Acumen and service provider, have a person, five people, ten people, a large team as well, on the ground for you. And this source, they recruit that person for you, on their payroll and manage that person to achieve your objective in a more compliant consulting service model. I’m trying to simplify a bigger thing here. That’s ICR for you. You have people on ground who are running around say, you are an incorporated structure, you are not a legal entity, you do not have a hassle of setting up an entity that takes you three to six months, you do not have a hassle of winding up which might take two years. You don’t need a bank account. You don’t need HR, you don’t need many other compliance issues there. You have a trusted partner like Acumen, who is managing everything for you. And trust me, India is a difficult market.
That’s when Adrian and I started why India? It’s a difficult market. And then we went into the other difficult market. So it has been simplified, the ease of doing and things are happening. But compliance is still one of the biggest issues. When we travel to meet our clients internationally and see them today. It’s one of those factors, what not a big factor to select an ICR kind of model. However, the way you handle an ICR can also somehow become tricky.
Yes, I’m able to set up quickly, I’m able to run on the ground quickly. I have a very fixed cost I know of a person or the budget, the travel, the marketing, and everything is all fixed. I know what I’m going to spend, and that is a very good thing, because sometimes you have a legal entity, it’s difficult to even budget certain kinds of compliances. But at the same time, you also have certain do’s and don’ts, which become like a rule book. You do need to follow that rule book to make sure that the ICR structure, the unincorporated structure, is a compliant structure for you.
When I say a compliant structure for you, it comes from two perspectives. One is you’re trying to achieve something in a way without setting up a legal entity. So why would a country allow you to do something without setting up a presence there. They want money, they want the foreign direct investment, they want a legal entity there, they want to generate employment, they want to have a bank account. They want you to have proper feet on the ground. If you don’t, which is unincorporated, it becomes a structure which you need to comply with, which means one of the bigger issues.
The Reserve Bank of India, which is our federal bank here in India, asked you to set up a structure and if you don’t, then you do need to inform them, if you do not follow the unincorporated structure. The second is the tax issue. When I say tax issue it’s a very simple language, that you are creating an establishment in India without creating it. You do not have a legal entity, but are you trying to do something which you were supposed to do when you have a legal entity? That means that you need to make sure you do not have any kind of permanent establishment in India, which is a word defined under Indian tax rules read relations, as well as something called double taxation avoidance agreements, which two countries signed together. So that one income should not be taxed twice.
India, US, India, UK, India, Australia and so on India have probably more than 90 such agreements signed with so many countries. That definition of parent establishment is very well defined there.What we need to do is a great ICS structure, let’s set up certain rules, do’s and don’ts, where you make sure you comply with it.
Now, what are those do’s and don’ts? Ha, it’s when I’m taking that pause is just from my perspective, as I have been trying to achieve those do’s and don’ts for years. And it’s not easy, because we are trying to achieve our objective as an idea to put higher education as a business, but at the same time, we are running on the ground and trying to achieve some shape or form of the fee, the income the profit, or say different activities right.
One of the basic rules is when you have a person on the ground, that person should not be treated as an employee of a foreign institution. There should not be an employer-employee relationship between these two entities a foreign institution and the Indian ICR. How to avoid that, is that person should ideally not be anywhere in the market, social media, your LinkedIn profile should not be quoting themselves as being the employee or having a very strong relationship, which term them as an employee with that institution. The ICR staff, that person on the ground should not be signing any binding agreement or a specific paper on behalf of an institution which could make the institution liable in India. And when I say liable, generally speaking, say a sales activity. I’m again using a corporate word, but sales is sales.
So for example, if you are going into the market, you are meeting a student and you’re saying here’s your offer letter, generally this doesn’t happen. But the ICR should not be having the authority to give an offer letter to the student. And that is why you see many times, the ICR teams have to eventually take permission from the international office, here is all the documents.
My job is to do the licensing for those documents, vouching those documents, but the ultimate decision maker is sitting somewhere in the international office. And that’s the logic behind why they have been operating this way, because we also do not want to create a tax presence for the institution.
There are a few more, for example, that the relationship and you work in the ICR in India, the ICR should also be working in more of a consulting model, which means that they are providing the consulting services on behalf of my Indian service provider, say Acumen, to the foreign institution. It’s more like a consulting model where Acumen signs an agreement with the foreign institution providing them consulting services and ICR is our advisor which is a dedicated advisor to you as a foreign institution and they are your face who is a dedicated person doing services for you. That mannerism of being an advisor consultant country person should be there. Furthermore, if I go a little further than it, more from a perspective of that, when the ICR is operating in India when they are going the question comes in, OK can I use the business card of the institution when I go in the market? What do I tell the agent whether I work for the institution or I work for Acumen? I mean, there are answers to that, how do you operate in the market eventually and at the end of the day, the ICR is working for the Indian service provider as an employee and they are the employee of the Indian service provider. They are working as an advisor to the foreign institution, which can be explained as a very straightforward simple model, which is working not only in India, when my team and I were setting the Sannam S4 Group offices in North America or in the UK.
There are those kinds of service models there as well in Vietnam and Malaysia when we were setting up there. Of course there is another step which they call P O which is a professional employer organisation and I don’t want to touch it, because that’s a definite no no in some shape or form for India, if I go further down the ICR person operating in India should not be a lone Road Warrior. And what I mean by that, that person or even the service provider should not be working only for one or two institutions.
There is a term in the Indian tax law which says dependent agent and what a dependent agent means that if the revenue of the Indian service provider is dependent upon one or two institutions, you are a dependent agent, which means that you’re working wholly for that institution only, you are a tax presence, there is no grey area. I mean, there is no other doubt there. If there is a lone warrior working and representing only one institution or say maximum two institutions, they are creating a tax presence, whether they and people sometimes come and ask me, Oh, I saw so and so person and he’s actually operating in India, why is the government not catching them? I just can’t answer.
I can only say we are 1.4 billion people, one day, the government might catch them. We are still beating China in population. So I don’t know when that 0.1 person person’s come or not. But the law is clear that that person will be treated as a very simple warrior.
I was just going to comment on that. I think there’s two things there, you’re talking about a permanent establishment from a tax perspective. But one of the things I’ve learned there’s, there’s many,similarities and differences between labour law and employment law in the US and India. But one thing that is quite common, is the analysis that is done to determine a consultant or an employee. And one of the things is that are they exclusive?
If they’re exclusive to you so its I guess, tax law violation, but I think also labour law, and labour compliance is an area where you can get kind of tripped up running that that model because the government of India or that any government has an interest in their people receiving benefits, and being part of the kind of official labour force. I think just another kind of twist there in terms of a compliance perspective.
Absolutely. Thank you, Michael. For that, I mean, one or two more. So for example, the performance appraisal of the ICR should be done by the Indian service provider, the decision on salary, the decision on bonuses, the increments, has to be with the Indian service provider. Again, why not create the employer-employee relationship between the two distinct entities, which is the Indian employee or ICR, as well as the foreign institution.
There are those kinds of soft areas, I would say if you’re not able to decide, just think of that you need to avoid creating that employer employee relationship, as well as for example, another don’t is the foreign institution as I said, do not have an incorporated version here as ICR. So which means they can’t say they have an office in India or any country they are setting up a similar model. They should not be on their website or these kinds of events, should be launching their office, once they have an ICR. They might say, Oh, I am launching my India office, there is no office, the office is an Indian service provider. So, again, very basic, whether out of 1.4 billion events somebody will get to know or not I don’t know, but the law is clear there. These are some of the straightforward, simple do’s and don’ts if you comply with them. It’s a great model.
Fabulous. Okay. We’re going to change tack on to the next topic. So it’s going to be back to you Kapil, in a second. We’re going to move on to digital delivery and online learning, which obviously could be a complete solution, it could be embedded as part of a course. There are implications Kapil, can you maybe quickly take us through?
Yes. The digital transformation in the higher education field is growing day by day. As you have seen the new regulations coming in you could see many other activities which are performed digitally. COVID has or Coronavirus over that couple of years has really pushed everybody to provide education in a more digital form and manner and the internet collation have also been coming up the age to improve themselves, how do you deliver the digital collaboration, our Indian institution is signing a partnerships with foreign institutions, where the job of the Indian institution is to fetch students and provided probably their own infrastructure to have the student do the course of a foreign institution sitting in their campus, that’s also possible the student can do the course sitting in his house and pay for that digital course online.
The compliance points or regulatory points are how and who is transferring the fees. So, if the student is making a fee payment directly to the foreign institution, you’re doing well. There is no compliance issue, because Indian regulation is not that strict or I would say regulated for our Indian parents or Indian resident making payments overseas.
The concept of withholding taxes is not very strictly followed or regulated. However, when an entity which is the Indian institution or a corporate sending their employees for a digital course, in their offices, then the withholding tax issue comes in withholding tax is nothing but a party in India making a payment to another party for a fees and they have to withhold 1015 20% tax. This then becomes some time issue like a cost because once you withhold a tax in India, then that tax might not be recoverable in your home country, even if India, US India, UK, India, Australia have the double taxation avoidance agreement, but it’s it’s a credit not a refund.
So, a credit means, if you are paying tax in your home country, then only you can claim the credit of the tax which is paid in India, but you are a nonprofit, you are not paying tax in your home country. So, there is zero tax there. So, this tax paid in India is a cost. So, either you build that tax in the agreement you have signed with the Indian corporate/Indian institution, you charge 10% 20% Extra than or you absorb this cost very tricky, important point, which many deals I have seen I personally negotiated even for Ivy League’s got stuck at the end, who will bear this 10 15% extra cost some time the cost is also GST.
Sometimes the cost is the new law which came into force in India a couple of years back called equalisation Levy, which is a tax on digital activity, like a digital fee, like a student paying online. So there is a tax called equalisation Levy. I won’t go any deeper, but it’s a very coming of age topic.
Perfect. OK. We’re three topics down, on to the fourth. So before we come to Michael, back to Kapil, again, this time on collaborations obviously would UGC change the TNE sessions. You’ll have heard earlier, this is a scenario that looks likely to present itself more frequently. So maybe you can just talk us through key considerations there.
I hope you might have heard about the new regulations which are coming to India. But before that, if I talk about the collaboration, it has been going for years. A foreign institution having a collaboration with the Indian institution, it’s towards dual degree training programs, and combined activities where you have been sharing the revenue for that fee, if I can put it in a further different language. Collaboration has been going for years, you need to pick and choose for that collaboration.
Do you need a structure or do you not? Again, if you are able to provide the services sitting in your home country, you don’t need a structure. But if you need academia, if you need to have people on ground, we have some of the institutions from both US and UK who have collaboration with Indian institutions and they have to fly in and fly out their staff. That goes back to my previous problem, something called permanent establishment.
I don’t know how many of you as representatives of foreign institutions know how many of the international staff travel to India in a year. There is a regulation which covers India, US, Australia, that if your staff travel to India for more than 90 days, in any 12 month period, you have a permanent establishment and I can give you in writing 99 person institutions that are not even tracking it. That’s the reason you see some time, the fly in fly out approach. It doesn’t work because you can’t be in the country all the time, but because the CFOs of the institution, the Vice Provost, they all know, it’s a tax issue. That’s why they are not choosing the fly in fly out approach. Because once your staff, your team, your international office, spend more than 90 days in India, cumulative, any staff of the institution, you create a permanent establishment. So coming back to this topic of collaboration, ideally speaking, if you need people on ground, you need some structure. If you can deliver it online, you’re doing well taking your fees back to your home country, with the holding taxes, just like that.
You could staff it through your partner as well, to a certain extent, right?
Here’s the ICR. So I see I didn’t stop it by Sir.
No, but I was saying, if you have a TNE kind of partner, if you’re partnering with an Indian institution, what types of resources would they be able to provide? I guess?
So if you or if you partner with so for example, the academic thinking?
I’m just thinking, you know, about professors?
It’s complicated, because, for example, a professor coming from us working with the Indian institution, whether that professor wants to leave his National Insurance, leave his job, which he was doing at the institution and take an employment with an Indian institution. No, he would say second me there. And that’s a form of establishment issue, because he wants to keep his US employment, National Insurance, everything there and still become an Indian employee, because he’s working for the Indian institution. How do you un-structure the complication around? That’s why we say it’s better if you hire the Indian staff, Indian nationals, rather than sending the professor and academia from overseas. Otherwise, you just do again, better fly in fly out approach.
Great. OK. We’re going to switch tack on to one final topic. So there have been two well, in fact, as a scene setter, so I joined the business in 2011 and there was a lot of talk at that time about something called the foreign education providers bill, which had been in circulation for a good amount of time before I arrived here. Roll forward to 2023 and there have been two major developments in that area. Michael, I know, you’re particularly interested in this topic. So I’m going to ask you to kick off with GIFT. I know, we heard yesterday from part of the GIFT team, but we’re taking a delegation down to GIFT on Monday, which we’re excited about, but maybe you could just give a bit of background and a few thoughts, and then we’ll come back to Kapital.
Yeah, sure. I think GIFT is a unique opportunity that was launched in the Finance Minister’s budget. Not this past February, but the February before that, the government is super keen on attracting higher education institutions certification bodies, they’ve really kind of expanded the types of institutions and organisations and curricula, that they’re welcoming to GIFT City in order to skill up and provide workforce and talent for the structure that they’ve developed there. It’is essentially a special banking zone, like a special economic zone, but for banking, to make it easier to do forex trading, and other kinds of financial transactions. I think India is looking at GIFT as an opportunity with this kind of special with creating a special jurisdiction to kind of ease off some of the complexities that are involved with the University Grants Commission, and challenges for opening up a campus through that route. So maybe we can pass that over to Kapil.
Why don’t you give part of the story on the recent UGC draft legislation that’s been issued?
I have been waiting 15 years and we have been pushing it and each time, we talk about let’s submit a paper to the ministry. Let’s push them to have some sort of a local presence. We have seen China, Dubai, Malaysia, and many other countries opening up to foreign institutions and having a campus. And finally, it’s here, after so many years of pushing, the regulation is still coming. So UGC, which is the university grant commission, which controls the higher education in India, like setting up institutions, they came up with this draft regulation, which allows the foreign institution to set up a campus.
This is separate to GIFT City. GIFT City is like as Michael said is a finance tax zone, which is a city within a state. And that’s where you do many things, you can set up a financial bank, you can set up a higher education campus, you can do all that tax free there. UTC is a university grant commission, allowing foreign institutions to set up campuses anywhere in India. And that has its own regulations, how much fees you can earn, how many years they allow you to do that, what kind of entity you need to set up? How do you bring money in, how much fees, you need to charge the students, there are certain draft regulations, which they have already published. We took those regulations, we gave our input, asked our partners, what if you want to set up what you want in this regulation, and we have already submitted our response. And in the next few months, I do see the final regulation should come. And that will be a big, big door opener. So for example, they are allowing up to a ranking of 500 institutions, they are allowed to even set up the application. So it’s getting there. I’m very, very hopeful that that will take us to the next level of having followed the journey and having further campuses of foreign institutions in India.
OK, perfect. The future’s bright. So with that, I’m afraid we have to draw to a close. So on behalf of the Seamless team, thank you for listening to us. Hopefully you found it useful. We’re here to answer questions now and into the future. So thanks very much. Thank you
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