Clarification in respect of advertising services provided to foreign clients.

Place of supply rules: advertising services to foreign clients treated as export when recipient is located abroad, subject to conditions.

Where an Indian advertising company provides end-to-end advertising services to a foreign client and separately contracts with media owners, the supplies are principal-to-principal and the company is not an intermediary; the recipient is the foreign client and the place of supply is the recipient's location outside India, so the service may be treated as export subject to export conditions. If the Indian company merely facilitates a direct contract between foreign client and media owner, it is an intermediary and the place of supply for its facilitation services is the supplier's location in India.