The Circular Financing Paradigm: Legal Implications of AI Mega-Deals | M S Sulthan
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The Circular Financing Paradigm: Legal Implications of Tech-Infrastructure Mega-Deals & Pathways for Startups

By M S Sulthan Legal Associates, Kozhikode | February 27, 2026 | Corporate Finance / Technology Law

The recent announcement of OpenAI’s historic $110 billion funding round at an $840 billion post-money valuation marks a watershed moment in corporate finance and global antitrust law. Driven by colossal investments from tech infrastructure giants like Amazon, SoftBank, and Nvidia, this deal cements the era of "circular financing" in the artificial intelligence sector.

In this novel model, crucial infrastructure providers (chipmakers and cloud hosts) inject massive capital into AI developers. The developers, bound by strategic agreements, subsequently use those exact funds to purchase compute and hardware from their new investors. While this creates a fiercely symbiotic ecosystem for the giants, it raises a labyrinth of complex legal questions. Here is an analysis of the legal landscape surrounding this model, and how smaller Indian and global players can strategically—and legally—adopt it.

1. Deconstructing the Legal Risks of "Circular" Mega-Deals

When an investor provides capital that is contractually earmarked to flow back to them as revenue (e.g., an AI developer's commitment to spend $100 billion on AWS and deploy Nvidia's hardware exclusively), it triggers intense regulatory scrutiny across three primary legal domains.

A. Antitrust and Competition Law

Regulators globally—including the FTC (USA), the CMA (UK), and the Competition Commission of India (CCI) under the Competition Act, 2002—view these arrangements with intense suspicion.

  • Market Foreclosure (Section 3 & 4 of Competition Act): The primary concern is whether locking a massive AI developer into a specific ecosystem unfairly shuts out competing hardware or cloud providers. In India, this is heavily scrutinized as an "Anti-Competitive Agreement" or an "Abuse of Dominant Position."
  • The "Quasi-Merger" Trap: Regulators are increasingly investigating whether these deep, intertwining partnerships are essentially unnotifiable mergers designed to bypass traditional antitrust merger review thresholds.

B. Securities Law and Accounting Standards (Revenue Round-Tripping)

In public markets, "round-tripping"—where Company A invests in Company B, only for Company B to immediately buy Company A's services—can be construed as artificially inflating Company A's top-line revenue.

SEBI and ICAI Scrutiny: In India, auditors apply strict standards (like Ind AS 115 - Revenue from Contracts with Customers) to determine if these transactions have genuine commercial substance. Furthermore, SEBI closely examines whether multi-billion dollar valuations are reflective of genuine market demand or are merely a byproduct of these closed-loop capital injections.

C. Corporate Governance and Fiduciary Duty

Board members face complex fiduciary challenges. When a startup's largest investor is also its most critical vendor, negotiating pricing and terms at "arm's length" becomes inherently difficult. Under Section 188 of the Companies Act, 2013, such Related Party Transactions require stringent disclosures and non-interested shareholder approvals to prevent the alienation of minority stakeholders.

2. How Smaller Players Can Adopt the "Strategic Tie-Up" Model

While smaller startups cannot command $100 billion cloud commitments, the underlying architecture of this model—trading equity for critical infrastructure or domain access—is highly adaptable. Smaller players can utilize this framework to secure resources without burning through limited cash reserves, provided they navigate the legal guardrails carefully.

Strategy 1: "Compute-for-Equity" or "Data-for-Equity" Agreements

Smaller AI developers, SaaS companies, or biotech startups can partner with mid-tier cloud providers, specialized hardware firms, or data-rich enterprise companies.

  • The Mechanic: Instead of raising purely liquid capital, the startup issues equity or convertible notes in exchange for guaranteed server credits, API access, or proprietary data licensing.
  • The Legal Guardrail (Tax & Valuation): Ensure these agreements are structured with clear, market-rate valuations. In India, under Section 56(2)(viib) of the Income Tax Act (often called the Angel Tax provisions), if you trade equity for cloud credits, the transaction must be backed by a strict Merchant Banker's valuation report. The cloud provider must also account for those credits at standard commercial rates to avoid accounting discrepancies.

Strategy 2: Structuring for Antitrust Compliance (The "Non-Exclusive" Clause)

The quickest way for a smaller partnership to attract regulatory scrutiny from the CCI is to sign aggressive exclusivity agreements that lock out competitors.

  • The Mechanic: Form strategic alliances that prefer, but do not legally mandate, the exclusive use of the investor's infrastructure.
  • The Legal Guardrail: Draft contracts with "Most Favored Nation" (MFN) clauses or non-exclusive preferred vendor statuses rather than absolute lock-ins. This proves to regulators that the startup remains an independent actor legally capable of switching vendors if the investor's technology lags or prices surge.

Strategy 3: Joint Venture IP Development

Mirroring OpenAI’s agreement to "jointly develop customized models for Amazon’s own engineering teams," smaller players can offer bespoke R&D to their investors.

  • The Mechanic: A niche AI startup (e.g., focused on legal tech or fintech) takes investment from a major corporate player. Part of the capital is earmarked for the startup to build a proprietary, internal tool specifically for that investor.
  • The Legal Guardrail: Establish crystal-clear Intellectual Property (IP) assignment clauses. You must legally delineate exactly who owns the Background IP (the startup’s foundational model) versus the Foreground IP (the specific custom tool built for the investor) to prevent the startup from being stripped of its core technological assets.

Strategy 4: Maintaining Arm’s-Length Corporate Governance

To protect founders and early-stage investors from being swallowed or dictated to by strategic corporate backers:

The Mechanic & Guardrail: Institute strict board protocols regarding vendor contracts. If a strategic investor takes a board seat (or observer rights), draft Shareholder Agreements (SHAs) and Articles of Association (AoA) that require majority approval strictly from disinterested directors (non-investor board members) for any vendor contracts signed with that investor's parent company.

Summary Takeaway for Founders

The OpenAI-Amazon-Nvidia triangle proves that in the modern tech economy, strategic infrastructure is just as valuable as liquid cash. Smaller players can successfully adopt this model by focusing on niche partnerships, provided they prioritize transparent tax accounting, avoid strict vendor lock-ins, and zealously protect their core Intellectual Property.

Frequently Asked Questions (FAQ)

1. Is "Compute-for-Equity" legal in India?
Yes, issuing shares for consideration other than cash is legally permissible under the Companies Act, 2013. However, the exact value of the services (compute/cloud credits) must be evaluated by a registered valuer, and proper PAS-3 returns must be filed with the MCA detailing the non-cash consideration.
2. Does revenue round-tripping attract SEBI scrutiny?
Absolutely. If a listed entity invests in a startup solely to have that startup immediately buy its products (inflating the listed entity's sales figures), SEBI and the ICAI view this as a potential manipulation of financial statements. The transactions must reflect genuine commercial necessity and arm's-length pricing.
3. What is an MFN (Most Favored Nation) clause?
In a startup-vendor relationship, an MFN clause ensures that the vendor (investor) guarantees the startup the best possible pricing or terms. If the vendor offers a better price to another client, they are contractually obligated to offer that same lower price to the startup. This helps alleviate antitrust concerns regarding unfair pricing.
4. How do we protect our Background IP in a strategic corporate partnership?
Your investment agreement and Master Services Agreement (MSA) must explicitly state that all pre-existing technology, algorithms, and models (Background IP) remain the sole property of the startup. The corporate investor is granted only a limited license to use it, not ownership.
5. Can the Competition Commission of India (CCI) block a strategic tech investment?
Yes. If an investment crosses certain asset/turnover thresholds (or the new "Deal Value" thresholds introduced in recent amendments), it requires prior notification and approval from the CCI. If the CCI believes the deal causes an Appreciable Adverse Effect on Competition (AAEC), they can block it or mandate structural changes.

Structuring a complex tech infrastructure deal or issuing equity for services? Contact our Corporate Advisory and Technology Law desk for strategic legal counsel.

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