## Place of Supply – Training and Performance Appraisal Services [Section 12(5) of IGST Act]

For training and performance appraisal services, the rule depends on whether the recipient is registered or not.

### Rule

Recipient	Place of Supply
Registered person	Location of such registered person
Unregistered person	Location where services are actually performed

### Rationale

For B2B (registered), the recipient's location ensures proper ITC flow.
For B2C (unregistered), the performance location is more practical since no ITC is involved.

Worked example

### Example 1

Example 1: A registered company in Delhi sends its employees for training at a venue in Hyderabad.

Recipient registered in Delhi
Place of Supply = Delhi (location of recipient)

### Example 2

Example 2: Mr. Y (unregistered, residing in Pune) attends a 3-day photography workshop in Goa.

Recipient unregistered
Service actually performed: Goa
Place of Supply = Goa

### Example 3

Example 3: A registered firm in Mumbai engages a trainer in Jaipur for a course held in Bangalore.

Recipient registered in Mumbai
Place of Supply = Maharashtra (Mumbai) – performance location is irrelevant for registered recipients.

⚠️ Common exam mistakes

Applying performance location even when recipient is registered – wrong; for registered persons, location of recipient applies.
Confusing training services with admission to events (12(6)) – admission has its own rule.
Not asking about registration status of recipient – this is the deciding factor.

Bare-Act text Section 12(5) · IGST Act, 2017 · click to expand

Section 12(5) of IGST Act, 2017 – The place of supply of services in relation to training and performance appraisal to – (a) a registered person, shall be the location of such person; (b) a person other than a registered person, shall be the location where the services are actually performed.

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Place of Supply of Training and Performance Appraisal [Section 12(5)]

Worked example

⚠️ Common exam mistakes