Packing services collected from Indian company by the overseas warehouse agent for materials supplied to overseas customers - Whether RCM to be paid

[Balaji Srinivasamurthy]

Dear experts,

The materials are exported from India and kept at a warehouse outside India (intermediary services). The materials are supplied locally from the warehouse to the overseas customer. Whether GST to be paid under RCM or not, if the warehouse agent collects the packing charges from the Indian company in foreign currency? I referred Section 2(11) of IGST Act for the definition of Import of Services and Circular No. 203/15/2023-GST dated 27.10.2023 where the department clarified after the omission of Section 13(9) of IGST Act, however, request detailed insight on this matter.

AI Summary

GST on overseas warehouse packing depends on who is invoiced; IGST RCM applies if exporter receives service (Sec 5 IGST) When goods exported from India are stored and packed at an overseas warehouse, GST liability depends on the contractual recipient of the packing service: if the foreign warehouse/agent invoices the Indian exporter, the place of supply is India and the service qualifies as import of services, so IGST is payable under reverse charge by the Indian company (with admissible ITC); if the agent invoices the overseas buyer, the recipient is outside India and RCM does not apply. Currency of payment is irrelevant, and onward supplies from the foreign warehouse to overseas customers fall outside GST.