GST Place of Supply – Complete Practical Guide for Goods, Services, Inter-State & Cross-Border Transactions

Quick Answer: What Is “Place of Supply”?

Place of supply (POS) is the statutory location determined under Chapter V of the IGST Act for a particular supply. It is one of the critical steps in deciding the correct GST treatment.

For goods: first identify the applicable rule under Sections 10 and 11—movement, bill-to/ship-to, no movement, installation, onboard supply, import or export.

For domestic services: start with Section 12 and then check whether a special category overrides the general B2B/B2C rule.

For cross-border services: Section 13 contains the general recipient-location rule and several specific exceptions, including immovable property, events, goods physically made available, intermediary services and certain financial/transport services.

Do not assume: supplier location = place of supply. That is true only for particular statutory categories; many transactions use the recipient's location or another prescribed location.

1. Legal Framework – Sections 10, 11, 12 and 13

Chapter V of the Integrated Goods and Services Tax Act, 2017 contains the principal place-of-supply provisions. CBIC's published IGST text sets out Sections 10 and 11 for goods and Sections 12 and 13 for services. citeturn0search0

Provision	Subject	Practical question
Section 10	Goods supplied within India, other than imports/exports	Where do the goods terminate, get delivered, get installed, or get taken onboard?
Section 11	Imported/exported goods	Is it an import or export, and where is the importer/exporter located?
Section 12	Services where supplier and recipient are in India	Is it B2B/B2C or a special service category?
Section 13	Services where supplier or recipient is outside India	Does the general recipient rule apply or does a specific exception apply?
Section 2(6)	Export of services	Are all statutory export conditions satisfied?
Section 2(14)	Location of recipient of services	Where is the relevant establishment receiving the service?

Core principle: Place of supply is a statutory test. The commercial destination, billing address, project site, GSTIN and bank-payment location can all be useful evidence, but none should automatically replace the applicable statutory rule.

2. Place of Supply of Goods – Sections 10 & 11

2.1 Goods Involving Movement

Where supply involves movement of goods, the general rule places the supply at the location where the movement terminates for delivery to the recipient. citeturn0search0turn0search16

Example: Supplier in Telangana dispatches machinery to a customer in Karnataka. The movement terminates in Karnataka for delivery. Subject to the complete transaction facts, the POS is Karnataka and the tax classification follows the inter-State framework.

2.2 Bill-to / Ship-to

Where goods are delivered by the supplier to the recipient or another person on the direction of a third person, Section 10 treats the third person as having received the goods for POS purposes and applies the statutory rule concerning that person's principal place of business. citeturn0search0

2.3 No Movement of Goods

If the supply does not involve movement, the POS is the location of the goods at the time of delivery to the recipient. citeturn0search0

2.4 Installation or Assembly

Goods assembled or installed at site have their POS at the place where they are assembled or installed. This is especially important for machinery, EPC and project contracts. citeturn0search0

2.5 Goods Supplied on Board a Conveyance

For goods supplied on board a vessel, aircraft, train or motor vehicle, the POS is the location where the goods are taken on board. citeturn0search0

2.6 Imports and Exports

Transaction	Section 11 POS
Goods imported into India	Location of the importer
Goods exported from India	Location outside India

3. Domestic Services – Section 12

Section 12 applies where the location of the supplier and recipient of services is in India. The first step is to identify whether a specific service category in Section 12 applies. If not, the default rule in Section 12(2) is used. citeturn0search0turn0search16

3.1 General B2B Rule

Registered recipient: the POS is generally the location of the registered person, subject to the special provisions of Section 12.

3.2 General B2C Rule

For a person other than a registered person, Section 12(2) uses the recipient's location where an address on record exists; otherwise the supplier's location. citeturn0search0

3.3 Important Special Categories

Service	Typical Section 12 POS rule
Immovable property / construction-related services	Location of the property; special treatment where property is outside India.
Hotel/accommodation	Location of property/boat/vessel.
Restaurant/catering, personal grooming, fitness, beauty, health services	Location where actually performed.
Training/performance appraisal	B2B: registered person's location; B2C: where actually performed.
Admission to events/amusement parks	Where event is held/park is located.
Organisation of events	B2B: registered person's location; B2C: event location, subject to statutory rules.
Goods transportation	B2B: registered person's location; B2C: location where goods are handed over for transportation.
Passenger transportation	B2B: registered person's location; B2C: place where passenger embarks for continuous journey.
Banking/financial services	Location of recipient on supplier's records, subject to the statutory proviso.
Insurance	B2B: registered person's location; B2C: recipient location on insurer's records.
Government advertisement	Special State/UT allocation mechanism specified in Section 12.

CBIC's GST flier provides a consolidated overview of these domestic service categories. citeturn0search16

4. Cross-Border Services – Section 13

Section 13 applies where the location of the supplier or the recipient is outside India. The default rule is generally the recipient's location, but specific subsections override it for particular services. citeturn0search0

4.1 General Rule

Default: place of supply is the location of the recipient of services. If the recipient's location is not available in the ordinary course of business, the supplier's location is used.

4.2 Services Requiring Physical Availability of Goods

Section 13(3) contains a special rule for services in respect of goods that must be physically made available to the supplier or a person acting for the supplier, subject to the statutory remote-service and temporary-import exceptions. citeturn0search0

4.3 Services Requiring Physical Presence of the Recipient

Where the service requires the physical presence of the recipient or a person acting on the recipient's behalf, Section 13(3) contains a specific performance-location rule. citeturn0search0

4.4 Immovable Property

Services directly related to immovable property, including relevant architectural, engineering, interior and construction-coordination services, generally follow the location of the property. citeturn0search0

4.5 Events

Admission to or organisation of specified events and ancillary services generally follows the location where the event is actually held, subject to the detailed statutory rules. citeturn0search0

4.6 Intermediary Services

Section 13 contains a special rule for intermediary services. The statutory definition covers a broker, agent or other person who arranges or facilitates a supply between two or more persons, but excludes a person supplying the goods/services/securities on their own account. citeturn0search0

Intermediary warning: Do not label a service “intermediary” merely because another supplier or customer is involved. CBIC Circular 159/15/2021-GST explains that a subcontractor supplying the main service on a principal-to-principal basis is not automatically an intermediary; it also states that the specific intermediary POS rule is relevant when either the supplier or recipient is outside India. citeturn0search17

4.7 Banking, Financial Account Services and Hiring of Means of Transport

Section 13(8) contains specific rules for specified banking/account-holder services, intermediary services and certain hiring of means of transport. citeturn0search0

5. Export of Services – POS Is Only One Condition

A service is not an export merely because the customer is outside India. The statutory definition of export of services requires all specified conditions to be satisfied, including supplier location in India, recipient location outside India, POS outside India, receipt of payment in the prescribed manner and the distinct-person condition. citeturn0search2

Export condition	Question to document
Supplier in India	Where is the supplier's relevant location?
Recipient outside India	Who is contractually receiving the service?
POS outside India	Does Section 13 actually place the supply outside India?
Payment	Is payment received in the prescribed manner?
Not merely distinct establishments	Are supplier and recipient separate persons for the statutory export test?

Important: A foreign-currency invoice alone does not prove export of services. First determine the recipient, service classification and POS under Section 13.

6. Special Service Categories – Practical Treatment

Construction / EPC
Identify whether the supply is directly related to immovable property, goods installed at site, or a general professional/service supply. The legal classification determines the POS rule.

Hotel & accommodation
POS generally follows the property location under the special rule.

Restaurant/catering
For domestic supplies, examine where the service is actually performed.

Training
Separate B2B and B2C rules; the registered recipient rule differs from the actual-performance rule for B2C.

Logistics
Goods transportation has specific domestic B2B/B2C rules; cross-border cases require Section 13 analysis.

Passenger travel
Embarkation rules become important for B2C continuous journeys.

Banking
Recipient records and account-holder classification can affect POS.

Insurance
Registered-person and unregistered-person rules differ.

SaaS/software
Do not assume every software service is an intermediary. Determine the actual supply and recipient.

Intermediary
Check whether the supplier arranges/facilitates another supply or supplies the service on its own account.

7. Business Transactions Where POS Errors Commonly Occur

7.1 Head Office and Multiple GST Registrations

For services to registered persons, the recipient's relevant GST registration/location can be important. Maintain the correct GSTIN in contracts, purchase orders and invoices rather than relying only on the corporate registered office address.

7.2 Multi-State Projects

For construction/EPC/project arrangements, separate the underlying supplies. A single commercial contract can contain goods, installation and services with different statutory POS implications.

7.3 Bill-to / Ship-to

For goods, use the specific Section 10 rule rather than assuming the delivery location is always the recipient's GSTIN State.

7.4 Third-Party Warehouses

Determine who is receiving the goods, who directed delivery, and where movement terminates. Warehouse location alone does not answer every POS question.

7.5 Foreign Customer, Indian Project

A foreign customer does not automatically create an export of service. If the service is directly related to immovable property located in India, the special Section 13 rule may place the supply in India.

7.6 Indian Supplier, Foreign Intermediary Customer

If the service is actually intermediary service, Section 13(8) can produce a different result from the general recipient-location rule. The intermediary characterization must be established from the contractual and operational facts. citeturn0search17

8. Place of Supply – Invoice, E-Invoice, GSTR-1 & Tax Impact

Place of supply should be determined before tax is charged. The GST invoice rules require the place of supply along with the State name for supplies in the course of inter-State trade or commerce. citeturn0search1

ContractSupplier locationRecipient locationSupply classificationPOSIGST / CGST+SGSTInvoiceGSTR-1

Error	Possible consequence
Wrong recipient GSTIN	Wrong POS/tax head and recipient-credit complications.
IGST charged instead of CGST+SGST	Tax classification mismatch and correction requirement.
CGST+SGST charged instead of IGST	Potential inter-State classification issue.
Wrong POS State on invoice	Invoice and return data may not support the intended tax treatment.
Export treated as domestic supply	Potential tax/refund/LUT consequences.

9. 32 Practical Place-of-Supply Cases

#	Scenario	Core POS analysis
1	Goods move Telangana → Karnataka	Movement terminates in Karnataka for delivery.
2	Goods delivered on buyer's instruction to third party	Apply the statutory bill-to/ship-to rule.
3	Machine installed at Maharashtra site	Goods installation rule applies.
4	Goods sold without movement	Examine location of goods at delivery.
5	Goods supplied on aircraft	Apply onboard-goods rule.
6	Imported machinery	Section 11 import rule; importer location.
7	Export of goods	POS outside India under Section 11.
8	Consulting to registered customer in Telangana	General domestic B2B rule, subject to special category.
9	Consulting to unregistered customer with address on record	Use Section 12(2) B2C rule.
10	Hotel room in Goa for Indian company	Property/accommodation rule.
11	Architect for property in Karnataka	Immovable-property rule.
12	Restaurant service in Hyderabad	Actual-performance rule.
13	Corporate training for registered customer	Check B2B training rule.
14	Training for consumer at venue	Check B2C actual-performance rule.
15	Ticket to event in Mumbai	Admission/event location rule.
16	Event organiser for registered customer	Apply B2B event-organisation rule.
17	Goods transport for registered recipient	Apply Section 12 goods-transport rule.
18	Passenger journey starting at Hyderabad	Check passenger transportation rule.
19	Insurance for registered company	Registered recipient rule.
20	Banking service for account holder	Check Section 12/13 banking provisions.
21	Indian consultant → US company	Start with Section 13 general rule, then test exceptions and export conditions.
22	Indian supplier repairs goods physically made available in India for foreign customer	Examine Section 13(3) physical-availability rule and exceptions.
23	Indian architect → foreign client for Indian property	Immovable-property exception can determine POS in India.
24	Indian event organiser → foreign customer, event in India	Apply Section 13 event rule.
25	Indian intermediary → overseas principal	Test intermediary definition and Section 13(8) rule.
26	Indian SaaS company provides own-account software to foreign customer	Do not classify as intermediary merely because software supports another business; test actual supply.
27	Indian agent arranges sales between foreign supplier and Indian buyer	Examine intermediary characterization.
28	Indian subcontractor performs main service for Indian prime contractor	Principal-to-principal supply is not automatically intermediary. citeturn0search17
29	Foreign customer hires Indian team for Indian construction site	Examine immovable-property relationship before calling it export.
30	Foreign customer buys remote IT/ITES service	General Section 13 rule unless a special provision applies; verify export conditions.
31	Multi-State property service	Apply statutory multi-State allocation mechanism.
32	Wrong State GST charged on invoice	Identify correct POS, tax classification and prescribed correction route.

10. GST Audit Questions on Place of Supply

Provide the POS determination policy used by the company.
How are supplier and recipient locations captured in ERP?
How are GSTINs mapped to business locations?
Provide inter-State versus intra-State tax reconciliation.
Identify invoices where POS State differs from recipient GSTIN State.
Explain bill-to/ship-to transactions.
Explain project-site supplies and installation transactions.
Review foreign-customer invoices classified as exports.
Provide LUT/refund documentation for export supplies, where relevant.
Explain intermediary classification for cross-border services.
Test construction, hotel, event and transportation supplies against special POS rules.
Reconcile POS on invoices with GSTR-1 data.
Review amended invoices and credit/debit notes.
Check whether e-invoice data carries the intended POS and tax classification.
Document exceptions where the ERP default rule was overridden.

11. 15 Common Place-of-Supply Mistakes

1. Using supplier State automatically POS is statutory, not a simple supplier-location rule.

2. Using billing address for every service Special rules may apply.

3. Ignoring recipient GSTIN Particularly risky for B2B services.

4. Treating project site as POS for every service First identify the exact supply.

5. Calling every foreign service an export Section 2(6) conditions must all be satisfied.

6. Ignoring Section 13 exceptions General recipient rule is not universal.

7. Calling every agent an intermediary Definition and own-account exclusion matter.

8. Ignoring bill-to/ship-to Goods have a specific statutory rule.

9. Ignoring installation Installed goods can have a different POS.

10. Wrong tax head POS drives inter-State/intra-State classification.

11. POS not reconciled with GSTR-1 Return data can perpetuate invoice errors.

12. No contract review Legal classification can depend on scope and recipient.

13. Ignoring multi-State services Allocation rules may apply.

14. Assuming payment location decides POS Payment location is not the universal statutory test.

15. No evidence file Keep contract, GSTIN, delivery, project and recipient-location evidence.

12. Place-of-Supply Decision Matrix

Step	Question	Next action
1	Goods or services?	Use the relevant Chapter V provisions.
2	For goods, is there movement?	Test Section 10(1)(a) and other specific goods rules.
3	Imported/exported goods?	Use Section 11.
4	For services, both parties in India?	Use Section 12.
5	Supplier or recipient outside India?	Use Section 13.
6	Is there a special service category?	Special provision overrides the general rule.
7	Is customer outside India?	Test Section 13 and all export-of-service conditions.
8	Correct POS determined?	Determine IGST vs CGST + SGST/UTGST and invoice accordingly.
9	Invoice issued?	Reconcile POS, State name and tax head with return data.

13. Place-of-Supply Documentation Checklist

ContractGSTINRecipient locationDelivery proofProject siteScope of workPOS analysisInvoiceGSTR-1Reconciliation

Document/control	Why keep it?
Purchase/sales contract	Shows actual scope and parties.
Customer GSTIN	Supports registered-person location.
Ship-to details	Critical for goods movement.
E-way bill/delivery documents	Supports physical movement and destination.
Project/site records	Important for installation and immovable-property services.
Foreign customer agreement	Supports recipient and service classification.
Export/LUT/payment records	Supports export-of-service conditions.
POS working paper	Shows why the tax head was selected.
GSTR-1 reconciliation	Confirms POS and tax classification reported correctly.

14. Frequently Asked Questions

Does place of supply always equal the customer's GST registration State?

No. That is an important general B2B service rule, but special rules for goods and specified services can produce a different POS.

Is the project site always the place of supply?

No. It depends on the nature of the actual supply. Installation of goods and immovable-property-related services have specific rules, while other services may follow recipient-location rules.

If my customer is outside India, is the service automatically an export?

No. The POS must satisfy the export definition and the other statutory export conditions.

What is the default rule for cross-border services?

Section 13(2) generally places the supply at the recipient's location, subject to the specific exceptions in Section 13.

What is the default rule for domestic B2B services?

Under Section 12(2), the general B2B rule is the location of the registered recipient, subject to special provisions.

Are intermediary services always exports when the customer is foreign?

No. Section 13 contains a special intermediary rule. The intermediary characterization itself must also be established from the actual functions and contractual arrangement.

Does a foreign-currency invoice prove export?

No. Currency of invoicing is not a substitute for the statutory export conditions.

Why is POS important for the invoice?

It is a key part of determining the correct inter-State/intra-State tax treatment, and the invoice rules require POS details in specified inter-State cases.

Key Takeaway

Place of supply should be treated as a transaction-classification exercise, not as an address-copying exercise.

Identify the supply → identify supplier and recipient → select Sections 10/11/12/13 → test special rule → determine POS → determine IGST or CGST + SGST/UTGST → invoice correctly → reconcile GSTR-1.

For businesses with construction, EPC, mining, logistics, multiple GST registrations or cross-border services, maintaining a short POS working paper for unusual transactions can substantially reduce classification errors.

GST Legal Reference Map

Section 10
Place of supply of goods other than imports/exports.

Section 11
Place of supply of imported/exported goods.

Section 12
Domestic services.

Section 13
Cross-border services.

Section 2(6)
Export of services definition.

Section 2(14)
Location of recipient of services.

Section 2(13)
Intermediary definition.

Invoice Rules
POS details and tax invoice requirements.

CBIC Circular 159/15/2021-GST
Important clarification on intermediary services.