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Taxation of cross border HO-BO business models

Date: 17 September 2024, 02:00 PM SGT
Host: Madhava Yathigiri 
Presenters: K. Baskar, Gaurav Bhauwala, and Bhupendra Kothari

In a recent issue covered by various media outlets, a major Indian MNC is in receipt of a notice for demand of INR 32,403 Cr as alleged non-payment of GST in relation to import of services by the Head office (“HO”) from overseas branch office (“BO”). 
This model is prevalent in the IT sector where companies are operating in a branch model. There has been plethora of judgements in the service tax regime in relation to HO-BO arrangements. However, disputes have arisen under the GST regime in respect of transfer of funds by the head office to the branch office to meet the branch office expenses. The current webcast would cover various business models and tax implications covering Indirect tax, Direct tax, and Transfer pricing in respect of HO-BO arrangements.

We will also discuss - 

•  Overview of various HO-BO business models
•  Documentation being maintained for various business models
•  Tax issues in respect of HO-BO arrangements
•  Key aspects to be considered for such arrangements
•  Judicial precedence in such cases

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