Intermediary services by Indian agents for foreign money transfer operators are taxable on commissions under place-of-provision rules. No service tax applies to the remitted money itself; however, Indian banks or entities acting as agents to foreign MTSOs perform intermediary services and, under the Place of Provision of Service Rules, the location of the Indian service provider determines the place of provision. Consequently, service tax is leviable on commission or fee received by Indian agents from MTSOs. Separately charged delivery fees to beneficiaries in India and currency conversion services performed in India are taxable; sub-agents are similarly intermediaries liable to service tax. This circular supersedes the earlier clarification dated 10 July 2012.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Intermediary services by Indian agents for foreign money transfer operators are taxable on commissions under place-of-provision rules.
No service tax applies to the remitted money itself; however, Indian banks or entities acting as agents to foreign MTSOs perform intermediary services and, under the Place of Provision of Service Rules, the location of the Indian service provider determines the place of provision. Consequently, service tax is leviable on commission or fee received by Indian agents from MTSOs. Separately charged delivery fees to beneficiaries in India and currency conversion services performed in India are taxable; sub-agents are similarly intermediaries liable to service tax. This circular supersedes the earlier clarification dated 10 July 2012.
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