CBEC issues clarification on applicability of Service Tax on
freight-forwarders as intermediary
In terms of Rule 10 of the Place of Provision of Services Rules,
2012 ['PPS Rules'], place of provision of the services of
transportation of goods, other than by way of mail or courier, is
the destination of the goods. Thus, place of provision of the
services of transportation of goods by air/ sea from a place in
India to a place outside India would be outside India and thereby
would not be subject to service tax. Further, Rule 9 of the PPS
Rules provides that place of provision of intermediary services is
the location of intermediary. The term intermediary is defined as a
person who arranges or facilitates the provision of a service or
supply of goods between two or more person, but does not include a
person who provides the main service or supplies the good on his
own account.
