Whether ISD Registration requirement in case of No Common Services

[PANKAJ MASKARA]

As per the Finance Act, 2024, ISD Registration is required for entities with multiple GST Registration under the same Pan.

However, if no common Services is being availed.

Please Clarify whether Registration is required.

[KASTURI SETHI]

    See the meaning and sense of the term, 'Common Input Service'  along with definition of ISD. {Emphasis is laid on the word, 'common'}.

  You have used the word, 'IF' before 'No Common Service'.

Pl. clarify and elaborate how services are not common. If services are not common, then what is the purpose of distributing the same to the other units under the same PAN.

            

[Raam Srinivasan Swaminathan Kalpathi]

Circular 199 dt. 17-Jul-23 should clarify this query.

[Shilpi Jain]

There may not be centralised procurement but there would be expenses incurred at company level like say Stat audit expenses, any business consultant services, etc.

Pls evaluate your expenses before coming to a conclusion.

[K.lakshmipati rao]

Slew of Common Services [other than Goods]:-

(i) Statutory Auditors Fee,

(ii) Internal Auditors Fee,

(iii) Company Secretary,

(iv) Professional Fee to CA for Certification charges,

(v) Security Services – [RCM],

(vi) Advocate Services [RCM],

(vii) Software Services,

(viii) Sponsorship Services,

(ix) Retainership fee,

(x) Advertisement, Digital and Marketing Services,

(xi) Lease Rent [RCM] and

(xii) Bank Charges [select transactions like Bank loan etc.,],

(xiii) Other common Services, if any, for ISD 

AI Summary

ISD registration requirement depends on existence of common input services; evaluate centralised expenses and benefit allocation under GST. Requirement for ISD Registration applies where multiple GST registrations exist under the same PAN and a centrally availed common input service is distributed to other units; absence of genuinely common or distributed services may negate the need for ISD, but a factual evaluation of company-level expenses and benefit allocation-such as audit, professional, software, marketing, retainership, security, advocate services, lease rent and select bank charges-is required. Administrative guidance (Circular 199) is cited for clarification.