Clarification on place of supply applicable for custodial services provided by banks to Foreign Portfolio Investors-reg

Place of supply for custodial services: treat as non-account holder supplies, apply default recipient location rule under GST.

Custodial services by banks to FPIs-consisting of safekeeping and maintenance of securities accounts-are not services provided to an account holder for the supplier-location rule. By analogy to prior Service Tax guidance, custodial, depository and trust services are excluded from the account-holder category and therefore the place of supply must be determined under the default place-of-supply rule, i.e., by reference to the recipient's location where ascertainable and otherwise the supplier, within the IGST framework.