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SEBI / Portfolio Managers

GST Treatment of PMS Fees — What Portfolio Managers Must Charge and Report

A comprehensive guide to GST treatment of PMS fees, including charging requirements, reporting obligations, and recent regulatory changes.

25 Jul 20263 min read

Goods and Services Tax (GST) is a critical consideration for portfolio management services. This article explains the GST treatment of PMS fees, charging requirements, and reporting obligations.

GST on PMS Services

Applicability

GST is applicable on services provided by portfolio managers to their clients. The service of portfolio management is treated as a taxable service under GST.

GST Rate

GST at the rate of 18% is levied on portfolio management fees. This includes:

  • Fixed management fees
  • Performance-based fees
  • Any other fees charged for portfolio management services

Basis of Charge

GST is charged on the fee amount, not on the underlying assets or returns.

Statutory Levies

Separate Charging

Statutory levies like GST, Securities Transaction Tax (STT), and stamp duty must be charged on actuals and listed separately.

Unbundling

SEBI has introduced unbundling requirements where statutory levies must be shown separately rather than being bundled into the headline expense cap.

Base Expense Ratio

The base expense ratio now separates fund management costs from statutory levies such as GST and securities transaction tax.

What Must Be Charged

Management Fees

GST must be charged on:

  • Fixed management fees
  • Performance fees
  • Advisory fees (if applicable)
  • Any other fee for portfolio management services

Transaction Costs

GST may also apply to:

  • Brokerage (if charged separately)
  • Custody charges
  • Other service charges

Statutory Levies

The following must be charged separately:

  • GST on fees
  • Securities Transaction Tax (STT)
  • Stamp duty
  • Exchange fees
  • SEBI fees

What Must Be Reported

Invoicing

Portfolio managers must issue proper GST invoices showing:

  • GST registration number
  • Taxable value
  • GST rate and amount
  • Total amount payable

Returns

Portfolio managers must file:

  • Monthly/quarterly GST returns
  • Annual GST returns
  • Any other returns as required

Client Reporting

Portfolio managers must separately disclose:

  • Management fees
  • Brokerage costs
  • Statutory taxes like GST and STT

Recent Regulatory Changes

Unbundling Requirement

The new rules require fund houses to separately list management fees, brokerage costs, and statutory taxes like GST and STT.

Base Expense Ratio

SEBI has introduced a Base Expense Ratio (BER), which separates fund management costs from statutory levies such as GST and securities transaction tax.

Actuals Basis

Charges such as securities transaction tax (STT), commodity transaction tax (CTT), GST, stamp duty, exchange fees, and SEBI fees will now be levied strictly on actuals and shown separately.

Compliance Checklist

For Portfolio Managers

  • Obtain GST registration
  • Charge GST at correct rate
  • Issue proper invoices
  • File returns timely
  • Disclose GST separately to clients
  • Maintain proper records

For Clients

  • Verify GST registration of portfolio manager
  • Ensure GST is charged correctly
  • Claim input tax credit if eligible
  • Maintain records of GST paid

Expert Legal Guidance

Anuj Desai & Associates provides expert legal advisory services on GST compliance for portfolio managers. Our tax and securities law experts help clients understand GST requirements, implement compliant processes, and ensure regulatory compliance. Contact us for guidance on GST and other regulatory matters.


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