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

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.