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Finin2minCurrent Action Brief · 13 Aug 2026
GST & Indirect TaxUpdated 5 October 2026

GST on Software Licence Plus Implementation and Support: Composite-Supply Classification

By Ravi Sisodia · Reviewed by CA Divyanshu Sengar · Updated 5 October 2026

2-minute summary

Current position

A software contract can include a licence/right to use software, implementation/configuration, migration, training and support. Whether the bundle is a composite supply depends on natural bundling and the principal supply. Perpetual/licence and SaaS structures also require careful classification and place-of-supply analysis, especially in cross-border arrangements.

Control and evidence map

#ControlWhat the file should show
1Break the contract into licence/subscription, implementation, migration, training and support deliverables.
2Identify pricing dependency and whether customers can buy components separately.
3Determine principal supply and document composite-supply rationale where used.
4Map supplier/recipient location and applicable place-of-supply/import rules.
5Reconcile milestone invoices, advances, credit notes and ITC to go-live/support periods.

Worked example

An Indian company buys a three-year ERP subscription plus mandatory implementation and data migration for one bundled price, while optional training is separately priced. The core package may support a composite-supply analysis around the software service, but the separately optional training should not be swept in automatically. If the vendor is overseas, RCM and import-of-service analysis must also be performed.

Common mistakes

  1. Treating every software contract as sale of goods or every SaaS contract as OIDAR without facts.
  2. Ignoring separately optional implementation/support components.
  3. Applying composite-supply treatment only because there is one invoice.
  4. Missing RCM/place-of-supply analysis for foreign vendors.

Frequently asked questions

Is implementation always part of the software licence?

No. Natural bundling, contractual dependency and normal industry practice matter.

Does one invoice prove composite supply?

No.

Can support after go-live be separate?

Yes, especially when separately contracted/priced and not integral to initial implementation.

What changes for an overseas vendor?

Import-of-service, RCM and place-of-supply rules must be tested on the actual supply model.

Official sources

Disclaimer: Educational and informational content only. Apply the current law, instrument, contract and facts before acting; obtain professional advice for material or disputed matters.

Disclaimer

Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.

Educational and professional reference only — not financial, tax or legal advice. Verify the current official position from the primary source before relying on any figure, rate, provision or deadline.