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Intermediary services supplied by overseas Local Area Representatives in film-production arrangements fall outside India's taxable territory where the producer retains exclusive creative, budgetary and business control. Representatives that arrange facilities, personnel and third-party shooting services for a fixed facilitation fee, without changing the nature or value of underlying services, act as intermediaries rather than film producers providing services on their own account. The specific place-of-provision rule for intermediary services applies, with Paris as the place of provision. Foreign tax incentives received through a representative do not establish independent film-production services. Consequently, reverse-charge service tax, related demand and penalties do not apply.
Intermediary services supplied by overseas Local Area Representatives in film-production arrangements fall outside India's taxable territory where the producer retains exclusive creative, budgetary and business control. Representatives that arrange facilities, personnel and third-party shooting services for a fixed facilitation fee, without changing the nature or value of underlying services, act as intermediaries rather than film producers providing services on their own account. The specific place-of-provision rule for intermediary services applies, with Paris as the place of provision. Foreign tax incentives received through a representative do not establish independent film-production services. Consequently, reverse-charge service tax, related demand and penalties do not apply.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
