In order for service tax to apply, it requires the provision of service from a service provider to a service recipient.
There is also the general acceptance of the principle that you cannot provide a service to yourself i.e. services
between departments in the same legal entity are not within the scope of service tax. However, there appears to
be less certainty in the case where that same legal entity consists of a non-resident corporate entity and its
resident branch.
Source: Deloitte
