A Services Agreement has a lifespan of 10 years. Trade in services particularly came about in 1995 with the establishment and growth of the WTO. All trade in services fall under the General Agreement on Trade in Services (GATS) Agreement. The legal structure of services comprises 4 tiers, namely: . Mode 1: Cross border supply Services delivered via telecommunications . Mode 2: Consumption abroad From one jurisdiction to another . Mode 3: Commercial Presence A state establishing a business in another . Mode 4: Movement of natural persons Contracting in a state for a limited period in order to deliver a service