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RCM on GTA used for export of goods

Rohit Jhunjhunwala

Is RCM payable on GTA if the GTA service is used for export of goods by road to Bhutan. Freight is paid by the supplier. The goods are exported on delivered basis.

Reverse charge on GTA services: exemption for transit-related exports to landlocked countries can remove RCM liability. Whether reverse charge is payable on GTA services used for road export to Bhutan turns on exemption coverage for transit-related supplies to landlocked countries; if exempt, no reverse charge is payable even when freight is paid by the exporter. If not exempt, the place-of-supply rules (transportation services deemed supplied at recipient location) determine whether the service qualifies as export of service, so reverse charge applicability requires factual analysis. (AI Summary)
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Sadanand Bulbule on Aug 20, 2025

Since GTA services used for export of goods by road to Bhutan are specifically exempted under Notification 12/2017-CT (Rate), Entry 19 (proviso), no GST under RCM is payable by the exporter, even if freight is paid by him.

Sadanand Bulbule on Aug 20, 2025

As a special case, RBI permits export proceeds from Bhutan to be received in INR as well.

Shilpi Jain on Aug 22, 2025

The mentioned notification exempts the below service w.r.t. export to Bhutan.

Supply of services associated with transit cargo to Nepal and Bhutan (landlocked countries).

So if yours is not transit cargo - exemption not applicable.

Though for transportation of services - place of supply is location of recipient - s 13(2). So it could be an export of service.

Pls look at facts.

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