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.
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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.
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