Question
XYZ(India) is receiving management consultancy
services from group / parent companies for the last one year. However, neither
the group / parent companies had issued invoice on XYZ till date nor XYZ had
paid any amount to group / parent companies due to some disputes. Is XYZ
required to pay GST on it under reverse charge even if payment not made to them
being the services received from group / parent companies?
Answer
As per Schedule-I of CGST ACT,2017 "Supply of
goods or services or both between related persons or between distinct persons as
specified in section 25, when made in the course or furtherance of business"
shall be treated as supply even if made without consideration.
A person who has obtained or is required to obtain more than one registration,
whether in one State or Union territory or more than one State or Union
territory shall, in respect of each such registration, be treated as distinct
persons for the purposes of this Act.
In your case XYZ is receiving services from group/parent companies (Distinct
person), then it will be treated as supply as per clause b of schdule-I if
provided even without consideration.
However reverse charge is not applicable on consultancy services as per
Notification No. 13/2017 Central Tax (Rate), but if parent Company is located
outside India then you are required to pay tax under reverse charge otherwise
liability to pay tax is on supplier of service i.e. Parent company
(Reply dt.12/01/2019)