Open market value applies to import of related-party services when full input tax credit is available. Clarification is issued on the valuation of import of services by a related person where the recipient is eligible for full input tax credit. The second proviso to Rule 28(1) of the APGST Rules deems the invoice value to be the open market value in cases involving related persons where full ITC is available, and this principle is stated to apply equally to import of services from a foreign affiliate to a related domestic entity. Where no invoice is issued, the value may be treated as Nil and still deemed to be open market value.