Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
This circular clarifies the determination of place of supply and export benefits for advertising services provided by Indian advertising agencies to foreign clients. Key points are: advertising agencies providing comprehensive advertising solutions, including media planning, content creation, and procurement of media space, are not considered intermediaries under IGST Act. The foreign client is the recipient, not their Indian representative or target audience. These services do not qualify as performance-based under IGST Act section 13(3). The place of supply is the location of the foreign recipient u/s 13(2), making it an export of services. However, if the agency merely facilitates media space procurement between the foreign client and media owner, acting as an intermediary, the place of supply is the agency's location u/s 13(8)(b). The circular provides clarity on export benefits eligibility for such advertising services to foreign clients.
This circular clarifies the determination of place of supply and export benefits for advertising services provided by Indian advertising agencies to foreign clients. Key points are: advertising agencies providing comprehensive advertising solutions, including media planning, content creation, and procurement of media space, are not considered intermediaries under IGST Act. The foreign client is the recipient, not their Indian representative or target audience. These services do not qualify as performance-based under IGST Act section 13(3). The place of supply is the location of the foreign recipient u/s 13(2), making it an export of services. However, if the agency merely facilitates media space procurement between the foreign client and media owner, acting as an intermediary, the place of supply is the agency's location u/s 13(8)(b). The circular provides clarity on export benefits eligibility for such advertising services to foreign clients.
Note: It is a system-generated summary and is for quick reference only.