Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Transfer of ESOP/ESPP/RSU by foreign holding company to employees of domestic subsidiary company does not attract GST where no additional fee, markup or commission is charged. Securities/shares are neither goods nor services under GST law. Reimbursement by domestic subsidiary to foreign holding company on cost-to-cost basis for transfer of securities/shares is not import of services. However, if foreign holding company charges additional amount over cost for facilitating/arranging transaction, GST is leviable on such additional amount payable by domestic subsidiary on reverse charge basis as import of services.
Transfer of ESOP/ESPP/RSU by foreign holding company to employees of domestic subsidiary company does not attract GST where no additional fee, markup or commission is charged. Securities/shares are neither goods nor services under GST law. Reimbursement by domestic subsidiary to foreign holding company on cost-to-cost basis for transfer of securities/shares is not import of services. However, if foreign holding company charges additional amount over cost for facilitating/arranging transaction, GST is leviable on such additional amount payable by domestic subsidiary on reverse charge basis as import of services.
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