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Corporate guarantees between related parties may constitute taxable supplies without consideration when made in the course or furtherance of business. Taxability must be determined before valuation; Rule 28(2) does not itself create a GST charge. For qualifying guarantees furnished to banks or financial institutions for related recipients in India, the rule generally deems the value to be one per cent of the guaranteed amount per annum or the actual consideration, whichever is higher. Where the recipient is eligible for full input tax credit, the invoiced value is deemed to be the supply's value. Relief granted for particular unremunerated subsidiary guarantees does not invalidate the rule or establish a general exemption.
Corporate guarantees between related parties may constitute taxable supplies without consideration when made in the course or furtherance of business. Taxability must be determined before valuation; Rule 28(2) does not itself create a GST charge. For qualifying guarantees furnished to banks or financial institutions for related recipients in India, the rule generally deems the value to be one per cent of the guaranteed amount per annum or the actual consideration, whichever is higher. Where the recipient is eligible for full input tax credit, the invoiced value is deemed to be the supply's value. Relief granted for particular unremunerated subsidiary guarantees does not invalidate the rule or establish a general exemption.
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