Service exports, GCCs and professionals
For IT, consulting and professional firms billing abroad — what makes a supply an export, the deeming provision that treated exports as local sales until it was removed, refunds on zero-rated supplies, and the transfer pricing questions a captive faces.
14 articles · written and reviewed by CA K Sanjay Bhargav, Chartered Accountant
Cornerstone guide
Export of Services: Realisation, FIRC and the GST Refund
Zero-rating gets you the invoice out. Getting the refund, and staying inside FEMA, both turn on a document the exporter usually only thinks about afterwards.
Cornerstone guide
Form 3CEB Is Now Form 48: What a Captive Actually Files
The transfer pricing chapter has been renumbered end to end, and so have its forms. Most of what is online still carries the old numbers on both.
Cornerstone guide
GCC and Captive Unit Taxation in India
The entity has one customer, no third-party revenue and no pricing power. Almost every tax question it faces is therefore about a transaction with its own parent — which is the hardest kind to defend.
Cornerstone guide
Intermediary Services GST: Section 13(8)(b) Omitted
For nine years an Indian firm earning foreign exchange for arranging business abroad was deemed to be supplying in India. That deeming provision has been deleted — but only prospectively.
Section 92CE Secondary Adjustment: Now Section 170
The transfer pricing adjustment is not the end of it. If the money stays abroad, it becomes a deemed loan carrying interest — and the rate the old rule points at no longer exists.
ESOP Recharge from a Foreign Parent: Deduction and Pricing
The recharge is usually treated as an accounting entry and examined as three unrelated problems. It is one transaction, and it tends to fail all three for the same reason.
Permanent Establishment Risk for a Foreign Parent
Every other question a GCC faces adjusts its own markup. This one moves the tax to the parent, and measures it on profits attributable to India.
The 2026 Safe Harbour Rules: 15.5% and a Wider Door
The margin came down, the threshold went up six-fold, and the block runs five years. A GCC that ruled safe harbour out under the old regime is working from a conclusion that no longer holds.
Secondment and Expat GST: A Fact Question, Not a Rule
The decision everyone cites was decided on its own facts and says so. What determines your answer is who employs the person, who controls them, and what is actually being recharged.
194J or 194C: Classifying Vendor Payments for TDS
The two provisions were consolidated into one table. The distinction between them was not — and the cost of choosing wrongly still lands on the person paying.
ESOP Taxation for Startup Employees: Two Taxing Points
The hard part is not the arithmetic. It is that the first tax falls due when you exercise, on a share you may not be able to sell for years.
Export of Services Under GST: The Five Conditions
Billing a foreign client in dollars feels like an export. Whether it is one depends on five separate tests, and failing any single one makes the whole supply domestic.
GST Refund on Export of Services: The Practical File
Entitlement is rarely the problem. Claims fail on evidence of foreign exchange receipt, on turnover figures that do not tie to the returns, and on periods that quietly went out of time.
Presumptive or Books: The 50% Question for Professionals
Presumptive is simpler, not automatically cheaper. If your real costs exceed half your receipts, the simplicity is being paid for in tax.
Other topics
- Tax notices and assessments
- Business tax, audit and filing
- GST — registration, returns and credit
- Foreign income, RSUs and ESOPs
- Bank finance and company compliance
- Internal controls, IT audit and data protection
- Manufacturing and industry
- Real estate, JDAs and development
- The Income-tax Act 2025 transition
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