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GST and indirect tax

GST place of supply advisory

Analyse location and supply facts before deciding how a transaction should be treated.

Illustration of financial records, a ledger and a business report.

Define the GST work

We map the parties, establishments, performance and contractual flow, then address the relevant place-of-supply question. The output states the facts assumed and the consequences for invoicing and reporting.

Describe the transaction in sequence: who contracts, who performs the work, who receives it and who pays. Identify the establishments involved and the period being assessed. Keep a proposed operating model separate from the arrangement already used in contracts and invoices.

Records needed for a useful assessment

  • Customer and supplier establishments
  • contracts
  • delivery or performance details
  • billing arrangement
  • intermediary roles
  • payment flow.

Provide the complete agreement and relevant work orders, together with evidence of delivery or performance. Explain any difference between the contracting party, invoice recipient and payment source. A transaction diagram can help organise those facts, but each important relationship should be supported by the underlying records.

A transaction detail that matters

A service performed remotely for an overseas group company needs more than the invoice address. The actual recipient and nature of the work must be understood.

For example, one group entity may sign the contract while another provides instructions and a third makes payment. Record the role of each party and the service actually supplied before drawing a conclusion. Group membership or an overseas remittance alone does not answer the factual question of who receives the supply.

What your proposal will cover

A conclusion applies to the described model. Changes in contracting entity or service flow need reassessment.

The written engagement confirms the GSTINs, periods, deliverables and responsibilities. Government payments and professional charges are identified separately.

The handover sets out the model assessed, confirmed facts, assumptions, reasoning and the-invoicing or reporting actions to consider. Identify which contractual or operational changes would require the position to be revisited. Historical invoices and any correction work should have a separate scope and decision record.

References and official procedures

The IGST Act is the legislative starting point for place-of-supply analysis. Confirm the applicable provisions, amendments and transaction period when preparing an opinion. The linked CBIC historical text was consulted on 2 October 2026; it is not a consolidated statement of current law.

Related starting points