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Goods and Services Tax

GST Place of Supply for Restaurant Training and Event Services

Summary: When the supplier and recipient are both in India, restaurant and catering services generally follow the place of actual performance; training changes according to whether the recipient is GST-registered; admission follows the place where the event is held; and event organisation or sponsorship follows the registered recipient’s location for B2B supplies but usually the event location for unregistered recipients. This article separates these easily confused rules, then shows how the place of supply and the supplier’s location determine whether IGST or CGST plus SGST or UTGST is charged.

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Start with the domestic transaction boundary in Section 12

Section 12 of the Integrated Goods and Services Tax Act, 2017 applies where both the supplier of services and the recipient are located in India. That boundary must be tested before choosing a sub-section. If either party is located outside India, Section 13 may govern and the matrix in this article cannot be copied across. For a domestic transaction, the place of supply is then identified under the most specific rule that fits the service actually supplied. The invoice label, accounting code or commercial description is relevant evidence, but it cannot override the substance of the contract.

After determining the place of supply, compare it with the supplier’s location. In the ordinary domestic case, different States or Union territories point toward an inter-State supply and IGST, while the same State or Union territory points toward an intra-State supply and CGST plus the relevant SGST or UTGST. This second step is essential: the place-of-supply rule does not, by itself, name the tax to charge. Special provisions, particularly supplies to an SEZ developer or SEZ unit, must also be checked before finalising the invoice.

Service supplied Recipient status Place of supply under Section 12 Invoice review focus
Restaurant, catering, grooming, fitness, beauty or specified health service Registered or unregistered Location where the service is actually performed Identify the establishment or performance location
Training or performance appraisal Registered person Location of the registered recipient Validate GSTIN and the recipient establishment receiving the supply
Training or performance appraisal Person other than a registered person Location where the service is actually performed Capture actual venue or performance location
Admission to an event or amusement park Registered or unregistered Place where the event is actually held or park/place is located Do not substitute the buyer’s billing address
Organisation of an event or sponsorship Registered person Location of the registered recipient Separate organiser’s service from admission tickets
Organisation of an event or sponsorship Person other than a registered person Place where event is actually held; special rule if held outside India Check venue and recipient location

Restaurant and catering services follow actual performance

Section 12(4) places restaurant and catering services, personal grooming, fitness, beauty treatment and specified health services at the location where the services are actually performed. The recipient’s GST registration does not switch this rule. A company registered in Maharashtra may book a business lunch at a restaurant in Karnataka; the restaurant service is performed in Karnataka. The supplier must then compare that Karnataka place of supply with its own location to determine the nature of supply and the tax components.

The practical difficulty is identifying the supply. A caterer preparing and serving food at a client’s venue is not necessarily in the same factual position as a restaurant delivering packaged food, a hotel providing accommodation with meals, or an event manager procuring catering as one component of a larger contract. Contracts and invoices should describe the principal supply and the actual performance location. Composite-supply analysis may be required; teams should not split or bundle charges merely to obtain a preferred place of supply.

Example restaurant bill for an out of State registered customer

Assume a Delhi-registered company’s employee dines at a restaurant located and registered in Jaipur. The restaurant service is actually performed in Rajasthan, so the place of supply is Rajasthan under Section 12(4). Because the restaurant supplier is also located in Rajasthan, the ordinary result is an intra-State supply, even though the customer provides a Delhi GSTIN. The recipient’s ability to claim input tax credit is a separate question and must not be used to alter the place shown on the tax invoice.

Training changes when the recipient is registered

Section 12(5) creates a deliberate B2B/B2C split for training and performance-appraisal services. When supplied to a registered person, the place of supply is the location of that person. When supplied to a person other than a registered person, it is the place where the services are actually performed. A training provider must therefore verify registration status for the relevant recipient and identify which establishment contracts for and receives the programme. Merely collecting any GSTIN from a corporate group is not a sound control.

For an in-person course held in Chennai by a Tamil Nadu supplier for a Karnataka-registered company, the B2B place of supply is ordinarily Karnataka, not the classroom venue. If the same course is sold directly to unregistered individuals and performed in Chennai, the place of supply is Tamil Nadu. Online or hybrid programmes require closer factual analysis of where the service is actually performed for an unregistered recipient and whether the service is genuinely training under Section 12(5) rather than an online information service or another category. The statute should be applied to the supply, not to a marketing label.

Scenario Supplier location Place of supply Ordinary tax direction
Tamil Nadu trainer serves Karnataka GST-registered company; class held in Chennai Tamil Nadu Karnataka Inter-State; IGST, subject to complete facts
Tamil Nadu trainer serves an unregistered individual; class held in Chennai Tamil Nadu Tamil Nadu Intra-State; CGST plus Tamil Nadu SGST
Maharashtra trainer serves Maharashtra GST-registered company; class held in Goa Maharashtra Maharashtra Intra-State, because registered recipient location controls
Goa trainer serves unregistered attendees; class physically held in Karnataka Goa Karnataka Inter-State; IGST, subject to complete facts

Admission tickets are not event organisation services

Section 12(6) covers services by way of admission to a cultural, artistic, sporting, scientific, educational or entertainment event, an amusement park or another place, together with services ancillary to that admission. The place of supply is where the event is actually held or where the park or other place is located. This rule applies whether the ticket buyer is registered or unregistered. A corporate GSTIN therefore does not move the place of supply for admission to a conference, exhibition or match.

By contrast, Section 12(7) addresses organisation of events and services ancillary to organisation, as well as assigning sponsorship of such events. For a registered recipient, the place of supply is the recipient’s location. For an unregistered recipient, it is the place where the event is actually held; if the event is held outside India, the recipient’s location applies. A conference organiser may consequently issue different invoices under different rules: one for organising the conference for a corporate client and another for admission sold to delegates. The team should map each contract and consideration rather than applying one venue rule to every revenue line.

Example corporate conference with delegate tickets

A Mumbai event company organises a conference in Hyderabad for a Bengaluru GST-registered client. The organisation service ordinarily takes the registered recipient’s Karnataka location under Section 12(7), producing an inter-State result against the Maharashtra supplier location. If the organiser separately sells admission tickets to delegates for the Hyderabad event, Section 12(6) points to Telangana for those admission supplies. The same physical event can therefore generate different places of supply because the legal supplies are different.

Multi State events require an allocation basis

Where an event covered by Section 12(7) is held in more than one State or Union territory and a consolidated amount is charged for services supplied to an unregistered person, the place of supply is treated as being in each relevant State or Union territory in proportion to the value for services separately collected or determined under the contract or agreement. In the absence of such a basis, the prescribed method applies. The allocation should be designed from commercial evidence such as venue days, separately priced modules, capacity, deliverables or another supportable value driver, rather than invented after the invoice is raised.

A tour, roadshow or training series may look like one campaign but still contain several supplies. The Section 12(7) multi-State event rule does not automatically govern training; Section 12(5) has its own rule. Likewise, separately sold admissions remain within Section 12(6). The contract should identify deliverables, recipient status, locations and consideration for each supply. The tax team should reconcile that map with e-invoice data, books, returns and customer documentation so that the declared place of supply is consistent across systems.

SEZ recipients override the ordinary same State conclusion

Section 7(5)(b) of the IGST Act treats supplies to an SEZ developer or SEZ unit as inter-State supplies. CBIC Circular No. 48/22/2018-GST specifically explains that short-term accommodation, conferencing and banqueting supplied to an SEZ developer or unit are treated as inter-State even where Section 12(3) otherwise points to the immovable-property location. The circular also explains that zero-rating for services supplied to an SEZ depends on receipt for authorised operations and the required endorsement and conditions. Businesses should therefore identify SEZ status and authorised-operation evidence separately from the general restaurant, training or event matrix.

Invoice controls that prevent place of supply errors

  • Classify the actual service: restaurant or catering, training, admission, organisation, sponsorship, accommodation or another supply.
  • Confirm that both supplier and recipient are in India before using Section 12.
  • Validate the recipient GSTIN and the relevant establishment; do not rely on a group company’s convenient registration.
  • Record the actual restaurant, performance, training or event venue whenever the applicable sub-section uses physical performance.
  • Separate admission consideration from event-organisation or sponsorship consideration in contracts and invoicing records.
  • For multi-State events, document a defensible contractual allocation and reconcile it with invoices and GST returns.
  • Check SEZ status, authorised operations and endorsement requirements before deciding inter-State treatment or zero-rating.

Frequently Asked Questions on Restaurant Training and Event Place of Supply

1 Does a customer GSTIN always determine the place of supply

No. It determines the place for training supplied to a registered person and for event organisation or sponsorship supplied to a registered person, but restaurant services follow actual performance and event admission follows the event location. The specific Section 12 rule controls.

2 Is a corporate conference ticket treated as event organisation

Not merely because a company buys it. A right of admission is governed by Section 12(6) and follows the event location. A service of organising the conference for a client is governed by Section 12(7). Contracts and deliverables must distinguish the two.

3 Where is B2B training supplied when the class is held in another State

For training supplied to a registered person, Section 12(5)(a) points to the location of that registered person. The physical classroom State does not replace that rule, although the correct recipient establishment and GSTIN must be verified.

4 Where is training supplied to an unregistered participant

Section 12(5)(b) points to the location where the training or performance-appraisal service is actually performed. Online and hybrid facts should be reviewed carefully rather than assuming the billing address or server location controls.

5 Can one event produce both IGST and CGST plus SGST invoices

Yes. Different supplies or recipients can produce different places of supply. Admission, organisation, sponsorship and restaurant services may fall under different sub-sections. Each invoice line must follow the applicable rule and supplier-location comparison.

6 Are services to an SEZ always zero rated

A supply to an SEZ developer or unit is treated as inter-State, but zero-rating and refund consequences require satisfaction of statutory conditions, including the authorised-operations requirement and prescribed evidence. SEZ status alone should not be used as a shortcut.

Key Takeaways

  • Restaurant and catering services follow where they are actually performed, regardless of customer registration.
  • Training follows the registered recipient’s location for B2B and actual performance for an unregistered recipient.
  • Admission follows the venue, while event organisation and sponsorship use a separate B2B/B2C rule.
  • Determine the place of supply first, then compare it with the supplier’s location to select IGST or CGST plus SGST or UTGST.
  • Multi-State events and SEZ supplies require additional allocation and evidence controls.

Source Links

  • Central Board of Indirect Taxes and Customs – Integrated Goods and Services Tax Act text, including Section 12: https://cbic-gst.gov.in/hindi/IGST-bill-e.html
  • Central Board of Indirect Taxes and Customs – Integrated GST legislation PDF: https://cbic-gst.gov.in/aces/Documents/IGST-bill-e.pdf
  • Central Board of Indirect Taxes and Customs – Circular No. 48/22/2018-GST on SEZ, accommodation and event-related services: https://cbic-gst.gov.in/pdf/Circular_48-22-2018-GST.pdf
  • Central Board of Indirect Taxes and Customs – GST flier on inter-State and intra-State supply: https://cbic-gst.gov.in/hindi/pdf/e-version-gst-fliers/eflier-meaning-scopeofsupply14062017.pdf

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Disclaimer: This article provides a general educational explanation of selected domestic place-of-supply rules for restaurant and catering services, training and performance appraisal, admission to events, event organisation and sponsorship under the Integrated Goods and Services Tax Act, 2017, based on official material checked on 20 October 2026. It is not a classification ruling, tax opinion or substitute for reviewing the complete contract, recipient and supplier establishments, GST registrations, invoice lines, actual performance locations, event venues, bundled supplies, consideration allocation, SEZ status, authorised operations, notifications, circulars and current return or e-invoice requirements. Section 12 applies only when both the supplier and recipient are located in India; cross-border facts may require Section 13 and can produce a different outcome. The examples deliberately simplify facts and do not decide input tax credit, rate, exemption, time of supply, valuation, reverse charge, registration, invoicing, e-invoicing, zero-rating or refund eligibility. Restaurant, accommodation, catering, admission, organising, sponsorship, online training and composite supplies can overlap, and their legal treatment turns on substance rather than invoice labels. Amendments, judicial decisions, advance rulings and later CBIC clarifications may affect a transaction. Suppliers and recipients should reconcile the proposed place of supply with the live law, applicable notifications, contractual evidence, GSTIN records and official portal data, and should obtain advice from a GST practitioner, chartered accountant, cost accountant or legal counsel for material or uncertain transactions. TaxGuru accepts no responsibility or liability for tax, interest, penalty, denied credit, refund rejection, registration exposure, reporting mismatch, commercial loss or any other consequence arising from reliance on this article without a transaction-specific review of current law and facts.

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Author Info

CA Sandeep Kanoi
Qualification: Graduate, CA in Job / Business, DD
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 22,412

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