How to Determine Value of supply of services in case of pure agent under GST

Rule-33 of CGST Rules 2017

33. Val­ue of sup­ply of ser­vices in case of pure — 

Notwith­stand­ing any­thing con­tained in the pro­vi­sions of this Chap­ter, the expen­di­ture or costs incurred by a sup­pli­er as a pure agent of the recip­i­ent of sup­ply shall be exclud­ed from the val­ue of sup­ply, if all the fol­low­ing con­di­tions are sat­is­fied, namely,-

  • the sup­pli­er acts as a pure agent of the recip­i­ent of the sup­ply, when he makes the pay­ment to the third par­ty on autho­ri­sa­tion by such recipient;
  • the pay­ment made by the pure agent on behalf of the recip­i­ent of sup­ply has been sep­a­rate­ly indi­cat­ed in the invoice issued by the pure agent to the recip­i­ent of ser­vice; and
  • the sup­plies pro­cured by the pure agent from the third par­ty as a pure agent of the recip­i­ent of sup­ply are in addi­tion to the ser­vices he sup­plies on his own

Expla­na­tion.- For the pur­pos­es of this rule, the expres­sion “pure agent” means a per­son who-

  • enters into a con­trac­tu­al agree­ment with the recip­i­ent of sup­ply to act as his pure agent to incur expen­di­ture or costs in the course of sup­ply of goods or ser­vices or both;
  • nei­ther intends to hold nor holds any title to the goods or ser­vices or both so pro­cured or sup­plied as pure agent of the recip­i­ent of supply;
  • does not use for his own inter­est such goods or ser­vices so pro­cured; and
  • receives only the actu­al amount incurred to pro­cure such goods or ser­vices in addi­tion to the amount received for sup­ply he pro­vides on his own

 

Illus­tra­tion.- Cor­po­rate ser­vices firm A is engaged to han­dle the legal work per­tain­ing to the incor­po­ra­tion of Com­pa­ny B. Oth­er than its ser­vice fees, A also recov­ers from B, reg­is­tra­tion fee and approval fee for the name of the com­pa­ny paid to the Reg­is­trar of Com­pa­nies. The fees charged by the Reg­is­trar of Com­pa­nies for the reg­is­tra­tion and approval of the name are com­pul­so­ri­ly levied on B. A is mere­ly act­ing as a pure agent in the pay­ment of those fees. There­fore, A’s recov­ery of such expens­es is a dis­burse­ment and not part of the val­ue of sup­ply made by A to B.

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