Clarification on place of supply applicable for custodial services provided by banks to Foreign Portfolio Investors


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This notification clarifies the place of supply for custodial services provided by banks to Foreign Portfolio Investors (FPIs). Previously, some tax authorities believed these services should be taxed where the bank is located, as per Section 13(8)(a) of the IGST Act. The Central Board of Indirect Taxes and Customs (CBIC) has issued this clarification to ensure consistent application of GST law across all field formations.

F. No. CBIC-20001/4/2024-GST Government of India Ministry of Finance Department of Revenue Central Board of Indirect Taxes and Customs GST Policy Wing North Block, New Delhi Dated the 26th June, 2024 To, The Principal Chief Commissioners/ Chief Commissioners/ Principal Commissioners/Commissioners of Central Tax (All) The Principal Directors General/ Directors General (All) Madam/ Sir, Subject: Clarification on place of supply applicable for custodial services provided by ba
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FAQ :

The notification clarifies the place of supply applicable for custodial services provided by banks to Foreign Portfolio Investors (FPIs).

Some field formations were taking the view that the place of supply for custodial services would be the location of the service provider (the bank), as per Section 13(8)(a) of the IGST Act.

The clarification has been issued by the Central Board of Indirect Taxes and Customs (CBIC) under the powers conferred by Section 168(1) of the CGST Act.

The clarification was issued to ensure uniformity in the implementation of GST law across different field formations regarding these specific services.

FPIs refers to Foreign Portfolio Investors receiving custodial services from banks.

 
Notification No : 220/14/2024-GST
Source : https://taxinformation.cbic.gov.in/view-pdf/1003201/ENG/Circulars
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