Clarification on various issues pertaining to taxability and valuation of supply of services of providing corporate guarantee between related persons.

Valuation of corporate guarantee services: GST based on higher of actual consideration or annual percentage of amount guaranteed, with charge mechanics clarified.

The provision of corporate guarantees between related persons to banks or financial institutions is taxable and, for guarantees issued or renewed on or after 26 October 2023, valuation is governed by Rule 28(2). The value equals the higher of actual consideration and one per cent per annum of the amount guaranteed (pro rata for periods under a year and multiplied by years for multi year guarantees). Tax is payable on issuance and on each renewal; domestic intra group guarantees are forward charged with invoicing, foreign issued guarantees to Indian recipients attract reverse charge, and recipients may claim input tax credit subject to conditions.