Establish a direct connection
A sufficiently close nexus requires identifiable goods or land existing when the service is performed. Physical work, storage, valuation and rights affecting identified property can meet the test. General research or market advice need not. A loan secured by property differs from a mortgage financing its acquisition. Apply the specific statutory provision and its exceptions rather than assuming an overseas payer makes every local service international.
Trace all direct beneficiaries
Start with the contract and then follow actual service delivery, obligations and accountability. A local subsidiary can directly benefit even where its overseas parent contracts and pays; incidental spillover recipients are different. From 1 January 2020 the stated provisions can cover local GST-registered direct beneficiaries, subject to all other conditions. Check their registration at the time of supply and keep contracts and flow evidence supporting the zero-rating conclusion.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
Read the official PDF ↗