Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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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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