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Microlesson · 5-min read

RCM - RBI Overseeing Committee and Security Lending

## RCM on RBI Overseeing Committee Members and Securities Lending

### (a) RBI Overseeing Committee

Services by members of Overseeing Committee constituted by RBI → To Reserve Bank of IndiaRCM (RBI pays GST).

### (b) Securities Lending Services

Services of lending of securities under the Securities Lending Scheme of SEBI → RCM (security borrower pays GST).

### How Securities Lending Works

In the SEBI Securities Lending Scheme, transactions happen through a Clearing Agent:

```

Lender (Ram) ──Securities──> Clearing Agent ──Securities──> Borrower (Hari)

<──Lending Fees── <──Lending Fees──

```

### Tax Treatment

Leg of TransactionMechanismWho Pays
Lender to Clearing Agent (lending fees)RCMClearing Agent pays GST
Clearing Agent to Borrower (lending fees)RCMBorrower (Hari) pays GST

### Key Point

Both legs of the transaction are under RCM. The clearing agent acts as intermediary and the actual lending arrangement is treated separately at each leg.

Worked example

### Example 1

Example: Mr. Ram (Lender) lends securities through Clearing Agent X to Mr. Hari (Borrower). Lending fees flow as: Hari → Clearing Agent X → Ram.

Analysis:

  • Service by Ram to Clearing Agent → RCM by Clearing Agent
  • Service by Clearing Agent to Hari → RCM by Hari

⚠️ Common exam mistakes

  • Treating securities lending as exempt because securities are not goods/services for GST - actually the lending FEE is taxable as a service
  • Charging FCM on either leg - both legs of securities lending under SEBI scheme are RCM
Bare-Act text Entries 12 and 16 of Notification 13/2017-CT(R) · Notification No. 13/2017-CT(R) dated 28.06.2017 · click to expand
Services supplied by the members of Overseeing Committee to Reserve Bank of India; Services of lending of securities under Securities Lending Scheme, 1997 of Securities and Exchange Board of India - tax shall be paid on reverse charge basis.
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