High seas sale transactions are characterised predominantly as...

High seas sale transactions are characterised predominantly as sales of imported goods where the buyer pays a composite invoiced amount including letter of credit charges and other seller-incurred costs. A trader that neither issues a letter of credit nor provides a payment guarantee does not render banking or financial services merely by recovering its letter of credit costs from the buyer. Those charges form part of the sale consideration, and transfer of title in goods by sale falls outside the definition of service under the post-negative-list regime. Because obtaining the letter of credit is incidental to executing the sale, the composite price cannot be split to tax the embedded charges separately as a service.