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of <h1>Indian Ad Firms' Foreign Services: Not Intermediaries, Foreign Clients Are Recipients, Supply Location Determines Tax Export Status.</h1> The circular clarifies the tax implications for Indian advertising companies providing services to foreign clients. It addresses three main issues: whether these companies are intermediaries, who the recipient of services is, and if the services are performance-based. It concludes that advertising companies are not intermediaries as they provide services on a principal-to-principal basis, with the foreign client as the recipient. The place of supply is the location of the foreign client, thus qualifying as an export of services. However, if the company acts merely as an agent, it is considered an intermediary, and the place of supply is the company's location in India.
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