NBFC Capital Treatment for Deferred Tax Assets and Liabilities
Current · Source: Reserve Bank of India · RBI/2008-09/494 · issued 09 Jun 2009 · ~2 min read
Quick answerRBI clarifies that NBFCs must deduct deferred tax assets (DTA) from Tier I capital, net of deferred tax liabilities (DTL), except DTA from accumulated losses which is fully deducted. DTL cannot be added to capital.
The rule, in the simplest words
NBFCs must subtract deferred tax assets (DTA) from Tier I capital, but only after removing any deferred tax liabilities (DTL) that are not from accumulated losses.
If the DTA comes from losses the bank has already taken, it is taken out of Tier I capital in full, without any adjustment for DTL.
Any DTL that is larger than the DTA (excluding the loss‑related DTA) cannot be used to reduce the loss‑related DTA or added to Tier I capital.
The DTL and DTA must be shown separately in the balance sheet under ‘Other Liabilities and Provisions’ and ‘Other Assets’ respectively.
How it plays out — a real example
A gold‑loan officer named Ramesh at a NBFC in Indore sees that the company has a DTA of ₹5 crore from past losses and a DTL of ₹2 crore from timing differences. He tells the finance team to subtract the full ₹5 crore from Tier I capital and then subtract the net ₹3 crore (₹5 crore DTA minus ₹2 crore DTL) from Tier I capital, ensuring the excess DTL is not added to capital.
What changed
This circular builds on the July 31, 2008 instruction by providing detailed computation rules for DTA and DTL in capital adequacy. It specifies that DTA net of DTL (excluding DTA from accumulated losses) must be deducted from Tier I capital, while any excess DTL cannot be used to offset DTA from losses or added to capital.
What it means for you
NBFCs must carefully segregate DTA into those from accumulated losses and others, and compute net DTA after adjusting for DTL. This ensures capital adequacy calculations reflect only tangible, realizable assets, tightening the quality of Tier I capital. Lenders need to update their capital computation models and reporting systems accordingly.
What you must do
Reclassify DTA and DTL in balance sheet under 'Other Assets' and 'Other Liabilities and Provisions' respectively.
Deduct intangible assets and current/brought-forward losses from Tier I capital.
Calculate DTA deduction: deduct DTA from accumulated losses fully, plus net of other DTA minus DTL.
Ensure any excess DTL over other DTA is neither adjusted against DTA from losses nor added to Tier I capital.
Update internal capital adequacy policies and reporting templates to comply with these rules.
Who it affects
All NBFCs, NBFC compliance and finance teams, Auditors reviewing NBFC capital adequacy
❓ Common questions
How should DTA and DTL be presented in the balance sheet?
DTL created by debit to revenue reserves or P&L should be under 'Other Liabilities and Provisions' as 'others'. DTA created by credit to revenue reserves or P&L should be under 'Other Assets' as 'others'.
What is the exact formula for DTA deduction from Tier I capital?
Deduct (i) DTA associated with accumulated losses, plus (ii) other DTA net of DTL. If DTL exceeds other DTA, the excess is neither adjusted against (i) nor added to Tier I capital.
Can DTL ever be included in Tier I or Tier II capital?
No. DTL is not eligible for inclusion in either Tier I or Tier II capital for capital adequacy purposes, as per the earlier circular and this clarification.
📜 Read the original circular — full text as issued by RBI
RBI/2008-09/494
DNBS.PD/ CC.No. 142 / 03.05.002 /2008-09
June 9, 2009
All NBFCs
Dear Sir,
Accounting for taxes on income- Accounting Standard 22- Treatment of deferred tax assets (DTA) and deferred tax liabilities (DTL) for computation of capital
NBFCs were advised vide DNBS (PD) C.C. No. 124/ 03.05.002/2008-09 dated July 31, 2008 that in terms of Accounting Standard 22, the tax effects of timing differences are included in the tax expense in the statement of profit and loss as deferred tax assets (DTA) (subject to the consideration of prudence) or as deferred tax liabilities (DTL) in the balance sheet.
Further that the balance in DTL account will not be eligible for inclusion in Tier I or Tier II capital for capital adequacy purpose and that DTA being an intangible asset, should be deducted from Tier I Capital.
2. In this connection it is further clarified that
a) DTL created by debit to opening balance of Revenue Reserves or to Profit and Loss Account for the current year should be included under ‘others’ of “Other Liabilities and Provisions.”
b) DTA created by credit to opening balance of Revenue Reserves or to Profit and Loss account for the current year should be included under item ‘others’ of “Other Assets.”
c) Intangible assets and losses in the current period and those brought forward from previous periods should be deducted from Tier I capital.
d) DTA computed as under should be deducted from Tier I capital:
(i) DTA associated with accumulated losses; and
(ii)The DTA (excluding DTA associated with accumulated losses) net of DTL. Where the DTL is in excess of the DTA (excluding DTA associated with accumulated losses), the excess shall neither be adjusted against item (i) nor added to Tier I capital.”
3. NBFCs shall comply with all instructions as above and also contained in the circular dated July 31, 2008 in this regard meticulously.
Yours sincerely
(P Krishnamurthy)
Chief General Manager-In-Charge
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2008-09/494 · issued 09 Jun 2009. The plain-English explanation above is BankPulse’s own independent summary.
Deduct intangible assets and current/brought-forward losses from Tier I capital.
Ensure any excess DTL over other DTA is neither adjusted against DTA from losses nor added to Tier I capital.
Update internal capital adequacy policies and reporting templates to comply with these rules.
📜 Compliance
Reclassify DTA and DTL in balance sheet under 'Other Assets' and 'Other Liabilities and Provisions' respectively.
Calculate DTA deduction: deduct DTA from accumulated losses fully, plus net of other DTA minus DTL.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are a Compliance officer at a bank this circular applies to (All NBFCs, NBFC compliance and finance teams, Auditors reviewing NBFC capital adequacy), your first concrete step on “NBFC Capital Treatment for Deferred Tax Assets and Liabilities” is: “Reclassify DTA and DTL in balance sheet under 'Other Assets' and 'Other Liabilities and Provisions' respectively.” (RBI issued this 09 Jun 2009).
Circular: RBI/2008-09/494 -- NBFC Capital Treatment for Deferred Tax Assets and Liabilities
Issued: 09 Jun 2009
Action required: Reclassify DTA and DTL in balance sheet under 'Other Assets' and 'Other Liabilities and Provisions' respectively.
Action required: Deduct intangible assets and current/brought-forward losses from Tier I capital.
Action required: Calculate DTA deduction: deduct DTA from accumulated losses fully, plus net of other DTA minus DTL.
Action required: Ensure any excess DTL over other DTA is neither adjusted against DTA from losses nor added to Tier I capital.
Action required: Update internal capital adequacy policies and reporting templates to comply with these rules.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.
💬 Banker Discussion
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BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=5025&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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