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of <h1>Custodial Services for FPIs: Place of Supply Based on Receiver's Location per IGST Act Section 13(2.</h1> The circular clarifies the place of supply for custodial services provided by banks to Foreign Portfolio Investors (FPIs) under the Integrated Goods and Services Tax Act, 2017 (IGST Act). It states that such services are not considered as services provided to 'account holders' as defined in Section 13(8)(a) of the IGST Act. Therefore, the place of supply for these services should not be determined based on the location of the service provider but rather under the default rule in Section 13(2) of the IGST Act, which considers the location of the service receiver. This clarification aligns with previous interpretations under the Service Tax regime.
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