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Service Tax on Foreign Bond Issue

Service Tax - Started By: - Dibyendu Ghosh - Dated:- 4-3-2016 Last Replied Date:- 5-3-2016 - Subsidiary of the client has issued Bonds in foreign country. The proceeds of the issue has been utilised by the subsidiary. Further, repayment of the proceeds has been made by the subsidiary.Service Tax Department is telling the Holding company to pay Service Tax under Full Reverse Charge on Issue related expenses. Contention of the Department is that as the guarantor is holding company, service tax has .....

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questions ? 4. Whether it is export of service or not, can be decided only after the above replies ? 5. If ST is applicable, primary responsibility is of subsidiary Co., if subsidiary co. is located outside India then holding company is liable to pay.(being in India) 6. Guarantor is legally bound for all financial liabilities of subsidiary co. Had holding co. not signed as guarantor, even then, it being parent co. and overall in control of all activities of subsidiary co.,cannot brush aside the .....

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