Facts of the case:

The Sports Management Private Limited an Indian company registered in India having its offices & operation centers in Mumbai.
The Sport Management conducts many running / walking events, both ‘on ground’ and on the digital / virtual platform. One such event that we are launching now, In this event iinternational participants are also being encouraged to register & participate in the event.
For the purpose of registration & receiving payment, a payment gateway link is being made and participants will pay a fee in US$ through the payment gateway, the payment gateway will then release the payment to the sport company as per their regular schedule.
The Companion mobile App will be downloaded by the participants and the participants can then participate from the international location of their choice.
The participants also can opt for event merchandise such as handbooks, medals & Kurta. The same will be couriered to them from India.

Queries related to GST:

Can it be contended that the services are being rendered outside India since the participants in the event are international in nature?
Under the above circumstances, is there a liability to collect GST from International participants?
What is the documentation necessary to be received from the payment gateway evidencing the fact that such remittances came out of the convertible foreign exchange from international participants?
Will the sport company be able to take credit for the GST and if so what is the procedure?
Any other query, you may like to clarify.

Hi Rohit,

Great set of queries! Let me break down the GST applicability and related points for your scenario involving international participants in your sports event.

1. Whether the service is rendered outside India?

Key points for GST place of supply (Section 13 & 14 of IGST Act):

The service is provided by an Indian company (supplier location: India).
The event participation happens from international locations (recipient location outside India).
The mobile app and participation is digital and consumed outside India.
Merchandise is physically sent from India to overseas.

What GST law says on Place of Supply:

For services, place of supply is where the service recipient is located.
Since the participants are outside India, the place of supply is outside India for the participation service.
Participation fees paid by international participants is thus treated as an export of service.

2. Is GST applicable on registration fees from international participants?

Participation fees (digital/on-ground participation service) qualify as export of service (Section 2(6) of IGST Act):
- Supplier in India
- Recipient outside India
- Place of supply outside India
- Payment received in convertible foreign exchange or Indian rupees wherever permitted by RBI.
Export of service is zero-rated under GST — no GST charged on such fees.
You need to comply with export documentation to claim zero-rating.

3. Is GST applicable on merchandise supplied to international participants?

Physical goods (merchandise) couriered from India to international participants qualify as export of goods.
Export of goods is also zero-rated under GST.
GST on inputs/input services used for export can be claimed as Input Tax Credit (ITC).

4. Documentation needed from payment gateway

Evidence that payment is from foreign currency remittance or convertible foreign exchange.
You can obtain:
- Payment gateway statement showing currency & source
- Bank realization certificate or foreign inward remittance certificate from your bank
This is important to prove export of service for zero-rating and to support GST refund claims.

5. Can the company claim Input Tax Credit (ITC)?

Yes, since the event is partly export of service/goods, GST paid on inputs and input services used for export is eligible for ITC.
To claim ITC:
- Maintain proper tax invoices.
- Ensure exports (service/goods) are properly documented.
- File GST returns timely (GSTR-1, GSTR-3B, etc).
You can also claim refund of unutilized ITC under zero-rated supplies by filing GST refund application.

6. Other considerations:

Place of supply of services related to event app used outside India is outside India.
If any Indian participants also participate, GST is applicable on their fees at applicable rates.
You should maintain clear segregation of domestic and export turnover.
For merchandise, ensure proper customs documentation for export.
Check RBI guidelines for foreign inward remittances compliance.

Summary Table

Aspect	GST Implication	Action Required
Participation fees by intl participants	Export of service; Zero-rated under GST	Maintain proof of foreign payment, file export documentation
Merchandise couriered abroad	Export of goods; Zero-rated GST	Customs export docs, maintain invoices
ITC on inputs/input services	Eligible for credit & refund	Maintain invoices & file returns timely
Payment gateway documentation	Needed to prove export & foreign inward remittance	Obtain payment & bank remittance certificates