GST AAR: Marketing, recruitment, and referral services provided to foreign universities and colleges qualify as “intermediary services”

Kerala Authority for Advance Ruling on treatment of marketing, recruitment, and referral services provided to foreign universities and colleges

Advance Ruling on Export of Services by Maryland Study Abroad Pvt. Ltd.

Vanshika verma | Sep 23, 2025 |

GST AAR: Marketing, recruitment, and referral services provided to foreign universities and colleges qualify as “intermediary services”

GST AAR: Marketing, recruitment, and referral services provided to foreign universities and colleges qualify as “intermediary services”

The Maryland Study Abroad Private Limited (Applicant) has filed an advance ruling dated April 16, 2025. The company is registered at address 27/1521/A1, Second Floor, Adakandy Building, Mavoor Road, Puthiyara, Kozhikode-673004 with GSTIN no. 32AAQCM7745KZW.

The applicant is an education consultancy service provider involved in private sectors. It provides comprehensive services related to the admission of students in India to foreign universities and colleges.

Questions Raised by Applicant

The applicant asked questions to seek the Kerala Authority for Advance Ruling (ARN AD321024003623V). The following are the questions:

Question 1:  Whether the marketing, recruitment, and referral services provided by M/s. Maryland Study Abroad Private limited to foreign universities and colleges on a principal-to-principal basis qualify as “intermediary services” as defined under Section 2(13) of the IGST Act, 2017, or whether they are considered independent services of a “marketing/recruitment/referral consultant”?

Question 2: Whether the services provided by M/s. Maryland Study Abroad Private, limited to foreign educational institutions, qualifies as an “export of services” in terms of Section 2(6) of the IGST Act, 2017, and is therefore not liable to GST?

Answers given by the ruling:

Following are the answers given by the Kerala ruling for the above-raised questions:

Answer 1: The marketing, recruitment, and referral services provided by M/s. Maryland Study Abroad Private limited to foreign universities and colleges qualify as “intermediary services” as defined under Section 2(13) of the IGST Act, 2017.

Answer 2: No. Services provided by M/s. Maryland Study Abroad Private Limited to foreign educational institutions do not qualify as “export of services”.

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