Summary: Tax authorities have long sought to levy GST on cross-border secondment arrangements by characterising them as “import of manpower supply services” under the reverse-charge mechanism. The Karnataka HC’s ruling in Huawei offers significant relief by holding that where expatriate employees are genuinely integrated into the Indian entity’s operations, the arrangement constitutes an employer–employee relationship excluded from the definition of “supply” under the CGST Act. Unlike NOS, where economic control over the employees never truly migrated to the Indian entity, Huawei demonstrates that substance must prevail over structure.Continue Reading When Tax Chases Talent Across Borders: Huawei and the GST dilemma on secondments