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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...
GST is payable under reverse charge mechanism on issuance of corporate guarantee without consideration by foreign group company to Indian subsidiary for loan taken from banks/financial institutions. The time of supply is the date of entry in books of Indian recipient. Prior to 26.10.2023, GST is payable at the time of execution based on valuation u/r 28(1). Post 26.10.2023, GST is payable one-time at 1% of total loan value u/r 28(2) at the time of execution. For continuing guarantees spanning multiple years, the value needs to be divided equally among relevant years, with GST payable at 1% of such divided value for the first year and 1% of outstanding loan value for subsequent years u/r 28(2).
GST is payable under reverse charge mechanism on issuance of corporate guarantee without consideration by foreign group company to Indian subsidiary for loan taken from banks/financial institutions. The time of supply is the date of entry in books of Indian recipient. Prior to 26.10.2023, GST is payable at the time of execution based on valuation u/r 28(1). Post 26.10.2023, GST is payable one-time at 1% of total loan value u/r 28(2) at the time of execution. For continuing guarantees spanning multiple years, the value needs to be divided equally among relevant years, with GST payable at 1% of such divided value for the first year and 1% of outstanding loan value for subsequent years u/r 28(2).
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