Place of Supply – Advertisement Services to Government [Section 12(14)]
## Place of Supply – Advertisement Services to Government [Section 12(14)]
This section applies to advertisement services supplied to Central/State Government, statutory body or local authority intended to be broadcast in multiple States/UTs.
### Rule
The place of supply is each State/UT where the advertisement is disseminated. The value attributable to each State is determined based on the contract or, in the absence of a contract, on a reasonable basis (e.g., circulation, viewership).
### Practical Application
If a Government Department in Delhi runs newspaper ads across Maharashtra, UP, and Tamil Nadu, the place of supply is split between these three States in proportion to circulation in each State.
### Note – Advertisement to non-Government recipients
(a) Sale of space / right to use space on hoarding/website for advertisement -> POS as per 12(3)(a) – the location of the property/space.
(b) Where an advertisement company wants to display ads on hoarding/billboards at specific locations -> POS as per general rule 12(2) (recipient location for registered; supplier/recipient as applicable for unregistered).
Worked example
### Example 1
Example 1: A Central Government department in Delhi commissions an ad campaign to be broadcast on TV channels across Maharashtra, Gujarat, and Rajasthan.
Place of Supply = Maharashtra, Gujarat, Rajasthan in proportion to viewership/agreed contractual values.
### Example 2
Example 2: A State Government in Kerala places newspaper ads in newspapers circulated in Kerala, Karnataka and Tamil Nadu.
Place of Supply = Kerala, Karnataka, Tamil Nadu based on circulation.
### Example 3
Example 3 (Non-Govt): A registered private company in Mumbai displays its ad on a hoarding in Bangalore via a vendor.
Sale of right to use space -> POS = Bangalore (Karnataka) [per 12(3)(a)]
⚠️ Common exam mistakes
Applying single place of supply (recipient's location) for multi-State Government ads – wrong; must split.
Confusing Govt-recipient ads with private-recipient ads – different rules.
Treating hoarding-space sale same as ad placement – they have different POS rules.
Bare-Act text Section 12(14) · IGST Act, 2017 · click to expand
Section 12(14) of IGST Act, 2017 – The place of supply of advertisement services to the Central Government, a State Government, a statutory body or a local authority meant for the States or Union territories identified in the contract or agreement shall be taken as being in each of such States or Union territories and the value of such supplies specific to each State or Union territory shall be in proportion to the amount attributable to services provided by way of dissemination in the respective States or Union territories as may be determined in terms of the contract or agreement entered into in this regard or, in the absence of such contract or agreement, on such other basis as may be prescribed.