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Advertising services to foreign clients are not intermediary services when the agency acts on its own account and supplies on principal-to-principal basis. Where an Indian advertising agency undertakes the entire advertising assignment for a foreign client on a principal-to-principal basis, it is not an intermediary and the foreign client remains the recipient of the service. The target audience in India, or an Indian representative of the foreign client, does not become the recipient where the contract, invoice, and payment are all between the agency and the foreign client. Such services are not performance-based services requiring physical presence and their place of supply follows the default rule as the recipient's location outside India, subject to export conditions. If the agency merely facilitates media space or broadcast between the foreign client and the media owner, it acts as an intermediary and the place of supply is the supplier's location.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Advertising services to foreign clients are not intermediary services when the agency acts on its own account and supplies on principal-to-principal basis.
Where an Indian advertising agency undertakes the entire advertising assignment for a foreign client on a principal-to-principal basis, it is not an intermediary and the foreign client remains the recipient of the service. The target audience in India, or an Indian representative of the foreign client, does not become the recipient where the contract, invoice, and payment are all between the agency and the foreign client. Such services are not performance-based services requiring physical presence and their place of supply follows the default rule as the recipient's location outside India, subject to export conditions. If the agency merely facilitates media space or broadcast between the foreign client and the media owner, it acts as an intermediary and the place of supply is the supplier's location.
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