GST on employee share transfers: cost reimbursements not import of services; markups or fees taxable on reverse charge. Where a foreign holding company issues ESOP/ESPP/RSU directly to employees of its Indian subsidiary and the subsidiary reimburses only the cost of the securities on a cost-to-cost basis, such reimbursement is not a supply of goods or services and is not liable to GST; however, any additional fee, markup, or commission charged by the foreign holding company is taxable as consideration for facilitation/arrangement services and attracts GST payable by the domestic subsidiary on reverse charge basis.