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SEBI / Stock Brokers

GST Cross-Charge Structuring for Multi-Entity Fund Management Groups

GST cross-charge structuring for multi-entity fund management groups explained. Learn about ISD, Rule 28 valuation, and cost allocation between entities.

15 Sept 20262 min read

Fund management groups often operate through multiple entities — the fund, the manager, the trustee, and shared service entities. Transactions between these entities trigger GST under the distinct persons and related party provisions. Cross-charge structuring ensures that these transactions are compliant and tax-efficient.

This article explains the cross-charge structuring framework.

The Distinct Persons Principle

Entities under the same PAN with different GSTINs are distinct persons. Transactions between them are supplies.

Cross-Charge vs ISD

  • ISD: For distributing ITC on common input services from external vendors. Mandatory from April 2025.
  • Cross-Charge: For internally generated services and non-ITC cost allocations.

Rule 28 Valuation

  • Where recipient is eligible for full ITC, nil-value invoice is acceptable.
  • Where full ITC is not available, open market value applies.

Documentation

  • Cost allocation workings.
  • Invoices.
  • GSTR-6 for ISD.

Conclusion

Multi-entity fund management groups need cross-charge structuring to ensure compliance and tax efficiency. A CA firm with fund expertise ensures that inter-entity transactions are structured correctly.

At Anuj Desai & Associates, we provide GST cross-charge structuring for multi-entity fund management groups. Our team handles ISD, Rule 28 valuation, and documentation.

For a confidential consultation, contact us at office@anujdesaiassociates.com or call 9619456656. Visit our website at https://anujdesaiassociates.com or connect with our founder on LinkedIn at linkedin.com/in/ca-anuj-desai-122547230.


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