GST on Visa Services: The Pure Agent Rule for Travel Agents

A customer pays you ₹12,860 for a Schengen visa. How much of that is GST? If your honest answer is "we put 18% on the total, roughly", you are probably overcharging the customer, overpaying the government, or both. If your answer is "we don't charge GST on visas", you are probably under-paying on the one part that is genuinely your income.

Visa billing is not hard once you see it as two different kinds of money moving through the same file: money you pay on the customer's behalf, and money you earn for your own work. GST law has a name for the first kind (the pure agent) and a rule for when you may leave it out of your taxable value. This guide walks through that rule, what the invoice should show, and the common mistakes.

What a "pure agent" actually is

Normally, everything you charge a customer for a supply is part of its value, and GST is worked out on that value. Rule 33 of the CGST Rules carves out one exception: costs you incur as a pure agent of the customer are excluded from the value of your supply, so long as all of these conditions are satisfied:

1. You act as the customer's pure agent when you make the payment to the third party, on the customer's authorisation.
2. The payment you made on their behalf is separately indicated on your invoice.
3. Those third-party supplies are in addition to the services you provide on your own account.

The rule then defines a pure agent as someone who has a contractual agreement with the customer to incur the cost for them, holds no title to what was procured, does not use it for their own interest, and, the one that matters most for pricing, receives only the actual amount incurred, in addition to what they charge for their own service.

The official illustration in the rule is close to visa work: a firm handling company registration recovers the Registrar's fees from the client on top of its own service fee. Those fees are compulsorily levied on the client, the firm is just paying them, so the recovery is a disbursement and not part of the firm's value of supply.

Rule of thumb: if the fee is levied on the applicant, the customer has asked you to pay it for them, you pass it on at the exact amount on the receipt, and it sits on its own invoice line, you are likely acting as a pure agent for it. The moment you add even ₹100 to it, it stops being a pass-through.

How the visa invoice should look

Here is an illustrative Schengen file. The amounts are made up to keep the maths readable; always use the figure on the actual embassy and VFS receipts.

Line	Amount	GST
Visa fee (government / embassy), paid on your behalf at actual cost	₹8,000	No GST added by you (pure-agent pass-through)
VFS service fee, paid on your behalf at actual cost	₹2,500	No GST added by you (pure-agent pass-through; the VFS receipt already includes VFS's own GST)
Visa service charge (heading 9985)	₹2,000	₹360 at 18%
Total	₹12,860

GST is ₹360, not ₹2,250 (18% of ₹12,500). That gap is the whole point of the rule, and it is real money on a family of four.

Alongside the usual invoice fields (your GSTIN, a sequential number, the customer's details and GSTIN for corporate clients, the CGST + SGST or IGST split), add a one-line note that the government and VFS/BLS fees were paid on the applicant's behalf as a pure agent, so you add no GST on them. Keep copies of the embassy and VFS receipts with the file; they are your evidence that you passed on the actual amount. Your general GST guide for travel agents covers the rest of the invoice basics.

Add-ons: courier, lounge, insurance, dummy tickets

Add-ons are where most of the grey area sits. The test is the same every time: did you pay a third party for the customer, at actual cost, on their say-so? Or are you selling your own service?

• Courier. If the customer asks you to book a courier for them and you pass on the exact receipt amount, it may qualify as a pass-through. If you use a courier to run your own service, such as sending files to VFS or returning passports you collected, it is normally part of your taxable charge. A flat "courier and handling" amount that includes your margin is your own service and taxable. Check with your CA which applies to you.
• VFS lounge / premium services. These are bought from the visa centre for the applicant. At the exact receipt amount, they usually behave like the VFS fee. Marked up, they don't.
• Travel insurance. The policy is issued by the insurer in the traveller's name. Discuss with your CA how you are paid for it (commission from the insurer, or a fee to the customer), because that decides where your taxable value is.
• Dummy ticket / hotel reservation for the application. If you are preparing it yourself and charging for that work, it is your own service and taxable. Treat it like your service charge.

When in doubt on a particular add-on, bill it as taxable and ask your CA. Charging GST you didn't need to costs the customer a little; leaving out GST you owed costs you the tax, interest and the argument.

Common mistakes on visa invoices

1. 18% on the whole amount. Overcharges the customer, makes your quote look expensive next to a competitor who bills correctly, and you pay tax on money that was never yours.
2. One line called "Visa charges". Condition two of Rule 33 asks for the third-party payment to be separately indicated. Lump it together and you have made it hard to show it was a pass-through at all.
3. Hiding your fee inside the embassy fee. Writing "Visa fee ₹9,500" when the embassy charged ₹8,000 breaks the "actual amount only" condition and puts your margin out of reach of GST. Show your fee as your fee.
4. No written authorisation. A booking form, signed application or even a clear written instruction from the customer asking you to pay the fees for them supports condition one. Ask your CA what is enough for your agency.
5. No receipts on file. If you cannot show the embassy and VFS receipts, you cannot easily show the pass-through was at cost.
6. Forgetting GST is a quoting issue, not just an invoicing one. If the customer was quoted "₹12,500 all-in" and you add ₹360 at invoicing, you have a conversation you didn't need. Quote the total with GST on the service charge from the start.

How TourBrain splits the visa invoice

In TourBrain's visa and passport desk, each file records its fees in separate fields: the government / embassy fee, the VFS / BLS fee, your service charge, and optional add-ons (courier, lounge / premium service, travel insurance, dummy ticket / hotel reservation, or other). The total the desk chases already includes 18% GST on your service charge, worked out the same way the invoice will, so the figure you quote is the figure you bill.

When you click "Create invoice", TourBrain raises a draft GST tax invoice with the embassy and VFS fees as separate pass-through lines kept out of your taxable value (no GST charged on them), your service charge as its own line at 18% under heading 9985, and the pure-agent note printed on the invoice. Add-ons start as pass-through lines. Tick "taxable" on any add-on you sell as your own service, or whenever you are not sure, and it is billed at 18%. Passport files work the same way, with the government passport fee as the pass-through. Receipts and refunds are tracked on the file, and on Professional and Enterprise, once the invoice is issued, you can send the customer a Razorpay payment link for the balance.

If the visa is part of a holiday, "Add visa fees" puts the same split onto the quotation: the government and VFS fees as pass-through lines, your service charge taxed. The visa desk is included from the Growth plan; see pricing for what each plan covers, and GST invoicing in TourBrain for the rest of the billing side.

TourBrain sets up the lines the way the rule describes. It does not decide whether a given fee qualifies for your agency: that is still a call for you and your CA. Start 14-day trial and bill your next visa file in two lines instead of one.

Last updated: 18 October 2026. This is general information for travel agency owners, not tax advice. The pure-agent conditions are quoted from Rule 33 of the CGST Rules, 2017; GST rates and notifications change, so confirm the treatment of every fee and the current rate on your service charge with your chartered accountant before you invoice.