Allocation of Corporate Product Manager cost 2 its Indian subsidiary,Will it be an import of service

[Sanjeev Sharma]

A foreign parent company allocates the cost of its Corporate Product Manager ( who looks after the particular businesss of all the companies in the group) to its all subsidiaries (including indian subsidiary Co.) around the world. For Indian subsidiary, will it be an import of service ? If yes, under which category ??

AI Summary

Import of service: allocation of corporate product manager costs may trigger tax as business auxiliary or management consultancy.
Whether a foreign parent's allocation of Corporate Product Manager costs to an Indian subsidiary is an import of service turns on whether the parent provides identifiable services to the subsidiary. Promotion or market development activities suggest business auxiliary services, while product design or advisory work suggests management consultancy. Mere cost allocation without substantive services requires detailed factual description to avoid import characterization.