This circular provides guidance on determining the place of supply for goods transport services, advertising services and co-location services. It explains that after removal of section 13(9) of the IGST Act, the place of supply for transport of goods (including mail and courier) in cross-border cases will follow the default rule of section 13(2): the recipient’s location, or the supplier’s location if the recipient’s location is not available.

For advertising services, two situations are addressed. When vendors sell space or rights to use hoardings (treated as immovable property), the place of supply is where the hoarding is located. When vendors merely display advertisements on structures they control, without transferring rights in the space, the service is treated as advertisement service and the place of supply follows section 12(2), based on the recipient’s location.

On co-location services, the circular clarifies that these typically involve hosting and IT infrastructure services, not renting of immovable property. Their place of supply is therefore determined by section 12(2), i.e., recipient’s location. Only when the arrangement is limited to renting physical space with basic infrastructure, without hosting-related functions, will it be treated as renting of immovable property and taxed based on the property’s location.