GST only on mark-up in case of issue of ESOPs to employees of Indian subsidiaries

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CBIC circulars clarify GST implications for foreign holding companies charging additional fees for Employee Stock Options. MNCs need precise documentation with parent/affiliate companies to avoid GST obligations. Reimbursements on a cost-to-cost basis exempt from GST. Services imported trigger GST under reverse charge. Domestic companies must understand and fulfill their GST payment responsibilities.