GST is leviable on the reimbursement of the subsidiary company to its ultimate holding company located in a foreign territory outside India.
Levy of GST- The instant appeal is filed against the order passed by the Tamilnadu State Authority for Advance ruling on the application for advance ruling filed by the appellant.
Appellant had filed an application seeking clarification on Whether GST is leviable on the reimbursement of the subsidiary company to its ultimate holding company located in a foreign territory outside India.
The lower authority held that the reimbursement is taxable at 18% at RCM as per 51. No 1 Notification 10/2017- Integrated Tax (Rate) dated 28.06.2017 as applicable to the service classification head 9971.
Held that- the Ruling pronounced by the Advance Ruling Authority is modified to the extent that GST is leviable on the reimbursement amount, being advance payment made by the holding company towards the cost incurred for the provision of Software Services supplied by the appellant, as per the Time of Supply provided under Section 13 of the CGST/TNGST Act 2017 and applicable rate is that applicable to the supply of Software Services made by them. The subject appeal is disposed of accordingly.
GST is leviable on the reimbursement of the subsidiary company to its ultimate holding company located in a foreign territory outside India.
Levy of GST- The instant appeal is filed against the order passed by the Tamilnadu State Authority for Advance ruling on the application for advance ruling filed by the appellant.
Appellant had filed an application seeking clarification on Whether GST is leviable on the reimbursement of the subsidiary company to its ultimate holding company located in a foreign territory outside India.
The lower authority held that the reimbursement is taxable at 18% at RCM as per 51. No 1 Notification 10/2017- Integrated Tax (Rate) dated 28.06.2017 as applicable to the service classification head 9971.
Held that- the Ruling pronounced by the Advance Ruling Authority is modified to the extent that GST is leviable on the reimbursement amount, being advance payment made by the holding company towards the cost incurred for the provision of Software Services supplied by the appellant, as per the Time of Supply provided under Section 13 of the CGST/TNGST Act 2017 and applicable rate is that applicable to the supply of Software Services made by them. The subject appeal is disposed of accordingly.