FORWARD CONTRACT SERVICES

 

[as introduced by the Finance (No. 2) Act, 2004]

 

Forward Contract services are brought under the service tax net by the Finance (No. 2) Act, 2004, w.e.f. 10-9-2004. The services shall be taxed if provided by a member of a recognised association or a registered association.

 

Rate of Service Tax: The rate of service tax is specified in section 66 of the Act. As per section 66, which covers charging of tax on aforesaid service, introduced by the Finance (No. 2) Act, 2004, rate of service tax on this service shall be 10% ad valorem. Further, the Finance (No. 2) Act, 2004 has also levied an education cess @ 2% of the service tax. The cess paid on inputs services shall be available as credit for payment of cess on output services. For further discussion in this regard, refer to 'Payment of Service Tax'.

 

'Forward contract services'

 

The definition of forward contract has been given under clause (46A) of section 65. That is:

 

'forward contract has the meaning assigned to it in clause (c) of section 2 of the Forward Contracts (Regulation) Act, 1952"

 

As per clause (c) of section 2 of the Forward Contracts (Regulation) Act, 1952:

 

"forward contract means a contract for the delivery of goods and which is not a ready delivery contract"

 

As per the provisions of Forward Contract (Regulation) Act, 1952, a forward contract is a contract for delivery of goods, which is not a ready delivery contract. For commodities notified under the Act, forward contracts can be entered into only through members of association recognized under that Act. For other commodities, future trading can be done through associations registered with Forward Market Commission. The levy of service tax under this category is on the services provided by members of such associations (commonly called as commodity exchanges) to any person in relation to forward contracts - reference Circular/letter F. No. B2/8/2004-TRU, dated 10th September 2004 (appended as Annexure 1).

 

Taxable service

 

The definition of taxable service provided by a member of a recognised association or a registered association has been given under sub-clause (zzy) of clause (105) of section 65. That is:

 

"any service provided "to any person, by a member of a recognized association or a registered association, in relation to a forward contract".

 

Liable to pay service tax

 

Service tax is liable to be paid when forward contract services are rendered by a member of a recognised association or a registered association.

 

 

(1) What is 'recognised association'?

 

"recognised association has the meaning assigned to it in clause (j) of section 2 of the Forward Contracts (Regulation) Act, 1952" [clause (89A) of section 65].

Section 2(j) provides as under:

 

"recognised association" means an association to which recognition for the time being has been granted by the Central Government under section 6 in respect of goods or classes of goods specified in such recognition;"

 

(2) What is 'registered association'?

 

"registered association has the meaning assigned to it in clause (j) of section 2 of the Forward Contracts (Regulation) Act, 1952 [clause (89B) of section 65].

 

Section 2 (j) provides as under:

 

"registered association" means an association to which for the time being a certificate of registration has been granted by the commission under section 14B."

 

Forward contract services are liable to be charged to tax

 

Forward contract services are liable to be charged to service tax when provided to

§         any person

§         in relation to forward contract

 

(1) Meaning of a 'person'?

 

The term 'person' has not been defined in the context of service tax. But, the term 'person' has been defined as "person shall include any company or association or body of individual, whether incorporated or not" [clause (42) of section 3 of General Clauses Act, 1897].

 

Therefore, even though, in general, person is understood as only natural person (i.e. human being) but in the context of service tax, it includes both natural and artificial and juristic person also. Thus, partnership firm, company, corporation, societies, government enterprises, Hindu undivided family (HUF), etc. will also fall under the definition of person.

 

Therefore, when service is provided to any of the aforesaid person, it will fall under the service tax net.

 

Value of taxable services for charging tax

 

The value of taxable services in relation to forward contract services provided by a member of a recognised association or a registered association to any person shall be the gross amount charged from any person in relation to forward contract [section 67]. The words 'gross amount' are used in contrast to the 'net amount', therefore, no abatement shall be allowed in respect of administrative/ office expenses incurred in respect of such services.

 

Explanation 1 has also been added to section 67, which provides that, for the removal of doubt, in respect of only certain specific services, it is declared that certain amount shall be part of value of taxable services and certain amount shall not be part of the value of taxable services, but nothing has been specified in respect of forward contract services.

 

Exempted services

 

(A) Exemption for the amount received prior to 10-9-2004

 

The Government, w.e.f. 10-9-2004 has exempted from whole of service tax, the portion of the taxable value, in respect of the 'forward contract services', which is received by the service provider prior to the 10th day of September 2004 [vide Notification No. 18/2004-ST, dated 10-9-2004 appended as Annexure VIII in the - 'Outdoor Caterer's Services']. It may be noted that the Government in its Circular No. 65/14/2003, dated 5th November, 2003 (appended as Annexure VII in the - 'Payment of Service Tax') had clarified that "where the value of taxable service has been received in advance for a service which became taxable subsequently, service tax has to be paid on the value of service attributable to the relevant month/quarter which may be worked out on pro rata basis". Further, w.e.f. 9-7-2004 the Service Tax Rules, 1994 have been amended vide Notification No. 5/2004-ST, dated 9-7-2004. As per the aforesaid amendment, where the value of taxable service is received before providing the taxable service, the service tax shall be paid on the value of service attributable to the relevant month, or quarter, as the case may be. In other words, where payment is received in advance, service tax will be payable on pro rata basis. Therefore, if the above exemption Notification would not have been issued then a service provider would be held liable to pay service tax on the portion of amount so received in advance before the imposition of levy of service tax which related to the portion of taxable services rendered on or after the date of imposition of service tax.

 

(B) General Exemption

 

The Government has granted exemption from the whole of Service Tax in respect of all taxable services, for services provided to United Nations or an International Organisation. Similarly, the exemption, subject to certain conditions, has also been granted for taxable service provided to a developer or units of Special Economic Zone (SEZ). The Government, w.e.f. 20 November, 2003 has restored the exemption, as an interim measure, from the whole of service tax when payment is received in convertible foreign exchange for the taxable services rendered in India provided it was not repatriated from or sent outside India, such exemption was earlier withdrawn w.e.f. 1-3-2003. The reader may note that detailed discussion about aforesaid exemptions along with relevant notifications have been given in the 'Exemption from Whole of Service Tax - Some Cases'.

 

N.B. The readers may note that provisions, procedures and other related discussion related to registration, payments of service tax, filing of return, interest and penalty, assessment procedure, appeal, refund of tax, etc., which are same, as applicable in respect of other taxable services, have been given in separate.

 

 

Annexure I

Issues pertaining to service tax - Regarding

 

Letter F. No. B2/8/2004-TRU, dated 10-9-2004, relevant extracts

 

10. Forward contract services: As per the provisions of Forward Contract (Regulation) Act, 1952, a forward contract is a contract for delivery of goods, which is not a ready delivery contract. For commodities notified under the Act, forward contracts can be entered into only through members of association recognized under that Act. For other commodities, future trading can be done through associations registered with Forward Market Commission. The levy of service tax under this category is on the services provided by members of such associations (commonly called as commodity exchanges) to any person in relation to forward contracts.