Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
Note: It is a system-generated summary and is for quick reference only.
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