Clarification regarding taxability of supply of securities under Securities Lending Scheme, 1997 - reg.
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Securities lending arrangements attract GST because temporary lending for a fee constitutes a taxable service.
Temporary lending of securities under the Securities Lending Scheme, 1997 is a taxable service rather than a transaction involving disposal of securities. The lending fee is consideration, while intermediary facilitation for commission or fee is separately taxable. The service is classified under heading 997119 and taxed at 18%. For the earlier period, the lender bears IGST under forward charge, without further IGST where CGST, SGST, or UTGST was already paid. From 1 October 2019, the borrower bears IGST under reverse charge mechanism.