In this clarification, the authority has explained in detail about the two conditions that are to be fulfilled in zero-rating the export of services. The Article 31(1) (a) of the ER specifies zero-rating of services exported to a recipient of services who does not have a place of residence in an implementing state and who is outside the state at the time the services are performed. The main concerns on zero-rating the services are given to non-resident is related to his residency and location when services are received. The amendment made in Article 31(2) on when a person shall be considered as ‘Outside the state’ is also explained in the clarification
Source: emiratesca.com
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