Articles 22nd Sep 2025

Ending the Tax Tussle: Export recognition for Intermediary Services under GST

Authors

Stella JosephPartner | Mumbai
Yash DesaiPrincipal Associate | Mumbai

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In a landmark move, India’s GST regime is set to undergo a significant transformation. The Government has announced a long-awaited clarification—intermediary services rendered in cross-border transactions will now qualify as exports, putting an end to years of ambiguity and tax disadvantage.

Under GST, at present, intermediary services are deemed taxable in India since the place of supply for such services is the location of service provider – denying Indian service providers the benefit of zero-rated exports, even when their services are rendered and consumed offshore. Similar position existed under the erstwhile Service Tax regime, where intermediary services were liable to service tax.

The proposed change marks a crucial shift:
✔️Aligns India’s indirect tax framework with global best practices
✔️ Unlocks export benefits for Indian intermediaries
✔️ Enhances India’s competitiveness in global service markets

However, the proposed change will now attract GST under the reverse charge mechanism for intermediary services, for Indian businesses availing such services from abroad, increasing compliance and cost considerations.

Against this backdrop, our Partner Stella Joseph and Principal Associate Yash K Desai have co-authored an article titled “Ending the Tax Tussle: Export recognition for Intermediary Services under GST” published on Bar and Bench.

Read the article here

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