Clarification regarding taxability of the transaction of providing loan by an overseas affiliate to its Indian affiliate or by a person to a related person
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Related-party loan transactions: interest-only lending remains exempt, while separately charged processing or administrative fees attract GST.
Loans, credit or advances between related persons constitute supplies, but interest or discount charged for extending them is exempt from GST. Where no amount other than interest or discount is charged, no separate loan-processing, facilitation or administrative service may be imputed merely because the parties are related, and no notional open-market value applies. Separately charged processing fees, administrative charges, service fees or loan-granting charges are consideration for taxable services.