Place of provision of service in case of modelling agency

Pops rule 4 place of provosion of performance based service

Means US this rule os subject to rule 7&8 rule 7-if service is provided also in taxable taritory then place would be that taxable tarritoy rule 8- provider reciever both of taxable territory then pops will be in taxable territory

The classification of the service would be important here. Also who is the recipient?

 

If the service is provided in India on Indian models then ST payable in  India even if the payment is recived inCFE form outside India. Rule 4(b) of POPS.

If service provided in USA for Indian Models and provided on behalf of US agency- not liable to ST.