TaxTMI 
TaxTMI 
Dogs Security
17 Apr 2019 
10 Replies 
8664 Views Asked by
Security service classification: whether provision of dogs constitutes taxable security services or a supply of live animals.
The central issue is whether provision of dogs for factory security is a taxable security service (subject to SAC classifications and possibly reverse charge when referring to supply of security personnel) or a supply of goods under Chapter 0106 (other live animals) possibly exempt from GST. Opinions diverge: some treat it as supply of security services using dogs (service SACs including watchdog or other security services), others argue "personnel" implies humans so RCM entries do not apply, while another view frames the transaction as sale of animals (requiring permanent alienation) rather than a service. (AI Summary)
The central issue is whether provision of dogs for factory security is a taxable security service (subject to SAC classifications and possibly reverse charge when referring to supply of security personnel) or a supply of goods under Chapter 0106 (other live animals) possibly exempt from GST. Opinions diverge: some treat it as supply of security services using dogs (service SACs including watchdog or other security services), others argue "personnel" implies humans so RCM entries do not apply, while another view frames the transaction as sale of animals (requiring permanent alienation) rather than a service. (AI Summary)
XYZ(Proprietor) is providing ‘Dogs’ to PQR (Body Corporate) for security of their factory premises. Is PQR liable to pay GST under reverse charge or XYZ need to pay under forward charge?