Reverse Charge Mechanism (RCM) under GST – Complete Guide with Rules, ITC & ISD Treatment
What is Reverse Charge Mechanism (RCM) in GST?
Under the normal GST system, the supplier collects GST from the recipient and pays it to the Government. However, under the Reverse Charge Mechanism (RCM), this responsibility is shifted from the supplier to the recipient of goods or services.
In simple words: Supplier does not charge GST. Recipient pays GST directly to the Government.
Legal Provisions Governing RCM
RCM is governed by the following provisions of GST law:
- Section 9(3) of the CGST Act, 2017
- Section 9(4) of the CGST Act, 2017
Section 9(3)
RCM applies to notified goods and services as specified by the Government.
Section 9(4)
RCM applies to specified supplies received from unregistered persons, only in notified cases.
When is RCM Applicable?
RCM is applicable when all the following conditions are satisfied:
- Supply is notified under GST law
- Supplier and recipient are located in India
- Supply is taxable under GST
- Recipient is registered under GST
Services Covered under RCM (Section 9(3))
Notification: 13/2017 – Central Tax (Rate)
|
Service
Description |
GST Payable By |
GST Rate |
|
Goods
Transport Agency (GTA) |
Recipient |
5% |
|
Legal
services by advocate |
Recipient |
18% |
|
Services by
director to company |
Company |
18% |
|
Sponsorship
services |
Recipient |
18% |
|
Import of
services |
Recipient |
18% |
|
Renting of
motor vehicle (specified cases) |
Recipient |
18% |
|
Security
services (manpower supply) |
Recipient |
18% |
|
Recovery
agent services |
Bank / NBFC |
18% |
Goods Covered under RCM
Notification: 4/2017 – Central Tax (Rate)
|
|---|
RCM under Section 9(4) – Unregistered Supplier
RCM under Section 9(4) now applies only to notified cases, mainly in:
- Real estate sector
- Supplies received by promoters
Notification: 07/2019 – Central Tax (Rate)
Payment of GST under RCM
RCM tax must be paid in cash only. Input Tax Credit cannot be used to discharge RCM liability.
Legal Reference: Section 49(4) CGST Act
Input Tax Credit (ITC) on RCM
Once GST is paid under RCM:
- ITC becomes eligible
- ITC can be claimed in the same tax period
Conditions under Section 16:
- Tax must actually be paid
- Goods or services must be received
- Used for business purposes
Time of Supply under RCM
For Goods – Section 12(3)
Time of supply is the earliest of:
- Date of receipt of goods
- Date of payment
- 30 days from the supplier invoice date
For Services – Section 13(3)
Time of supply is the earliest of:
- Date of payment
- 60 days from invoice date
Accounting Entries for RCM
Example: Legal service value ₹10,000, GST @18% = ₹1,800
RCM Payment Entry
Legal Expense A/c Dr. ₹10,000
RCM CGST A/c Dr. ₹900
RCM SGST A/c Dr. ₹900
To Cash / Bank A/c ₹1,800
ITC Claim Entry
Input CGST A/c Dr. ₹900
Input SGST A/c Dr. ₹900
To RCM CGST A/c
To RCM SGST A/c
Treatment of RCM under ISD
ISD cannot pay RCM tax. It only distributes eligible ITC to branches under Rule 39 CGST Rules, 2017.
Practical Flow: RCM + ISD
- Head Office receives RCM service
- Head Office pays GST in cash under RCM
- HO claims ITC
- ITC distributed to branches via ISD
Distribution of RCM ITC through ISD
- RCM ITC is an eligible credit
- Distributed under Rule 39(1)(c)
- Units under the same PAN
- Proportional distribution based on turnover
Common Mistakes in RCM Compliance
- Paying RCM tax using ITC
- Claiming ITC without payment
- Incorrect time of supply
- Showing RCM in GSTR-1
- Paying RCM through ISD registration
Reporting of RCM in GST Returns
| Return | Reporting |
|---|---|
| GSTR-1 | Not reported |
| GSTR-3B | Table 3.1(d) |
| GSTR-2B | Not auto-reflected |
Conclusion
RCM is one of the most technical areas under GST. Correct understanding of:
- Applicable sections
- Notified services
- Time of supply
- ITC eligibility
- ISD treatment
is essential to avoid interest, penalties, and compliance issues.
Important Sections, Rules & Notifications – Summary
| Provision | Purpose |
|---|---|
| Section 9(3) | Notified RCM supplies |
| Section 9(4) | URD supplies |
| Section 12(3) | Time of supply – goods |
| Section 13(3) | Time of supply – services |
| Section 16 | ITC eligibility |
| Section 49(4) | Cash payment |
| Rule 39 | ISD mechanism |
| Notification 13/2017 | RCM services |
| Notification 4/2017 | RCM goods |
Hope this article helps you to understand RCM.
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