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of The CBIC has clarified the following key points regarding taxability and valuation of supply of services of providing corporate guarantee between related persons: Sub-rule (2) of Rule 28 of CGST Rules prescribing 1% valuation applies to corporate guarantees issued/renewed on or after 26.10.2023. For prior periods, valuation to be done as per then existing Rule 28. Value is based on amount guaranteed, not loan disbursed. ITC can be availed irrespective of loan disbursal. For co-guarantors, GST payable proportionately at 1% of respective amounts guaranteed. For intra-group guarantees, GST payable under forward charge by issuer. For guarantees by overseas entities, reverse charge applies. Valuation at 1% per annum or actual consideration, whichever higher. Second proviso to Rule 28(1) benefit available. The 1% valuation not applicable for export of this service.
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