Reverse Charge Mechanism (RCM) is a system under GST where the recipient of goods or services pays tax instead of the supplier. It ensures tax compliance in cases where the government finds it difficult to collect from suppliers, like in unorganized sectors or specified transactions.
Key Takeaways
- RCM shifts tax liability from supplier to recipient in specific notified cases.
- It applies differently for notified supplies, purchases from unregistered dealers, and certain e‑commerce situations.
- RCM ensures better tax tracking, especially for high‑risk goods or services.
- Input Tax Credit (ITC) is available to the recipient if used for business purposes.
- Compliance under RCM requires timely payment, accurate reporting, and GST registration.
Reverse Charge Mechanism (RCM) is a provision under GST where the liability to pay tax is on the buyer of goods or services instead of the seller. This method helps the government cover transactions prone to tax evasion or difficult to monitor. The recipient must self‑invoice (if needed) and pay GST directly to the government.
The provisions of Reverse Charge Mechanism (RCM) are defined under the following laws:
Let’s break each down in simple language with examples:
Certain notified goods and services require the recipient to pay GST instead of the supplier. This typically applies where suppliers are unorganized or numerous, making it hard to track tax payments.
For example:
A company hiring a Goods Transport Agency (GTA) for freight services must pay GST under the reverse charge mechanism.
List of Notified Goods Under Section 9(3):
S. No. | Description of Supply | Supplier of Goods | Recipient of Supply |
1 | Cashew nuts, not shelled or peeled | Agriculturist | Any registered person |
2 | Bidi wrapper leaves (tendu) | Agriculturist | Any registered person |
3 | Tobacco leaves | Agriculturist | Any registered person |
4 | Essential oils (peppermint, spearmint, water mint, horsemint, bergamot) | Any unregistered person | Any registered person |
5 | Silk yarn (manufactured from raw silk or silk worm cocoons) | Manufacturer of silk yarn | Any registered person |
6 | Raw cotton | Agriculturist | Any registered person |
7 | Supply of lottery | State Govt., UT, local authority | Lottery distributor/selling agent |
8 | Used vehicles, seized/confiscated goods, old & used goods, waste, scrap | Central Government (excluding Indian Railways), State Govt., UT, local authority | Any registered person |
9 | Priority Sector Lending Certificate | Any registered person | Any registered person |
10 | Metal scrap | Any unregistered person | Any registered person |
List of Notified Services Under Section 9(3):
S. No. | Description of Service | Supplier of Service | Recipient of Service |
1 | Services by Goods Transport Agency (GTA) for transportation of goods by road to specified entities | Goods Transport Agency (GTA) | Factories, registered persons, corporate bodies, casual taxable persons in taxable territory |
2 | Legal services supplied by individual advocate, senior advocate or firm of advocates | Individual Advocate or Advocate Firm | Any business entity in taxable territory |
3 | Services by an arbitral tribunal to a business entity | Arbitral tribunal | Any business entity in taxable territory |
4 | Sponsorship services to a body corporate or partnership firm | Any person other than body corporate | Body corporate or partnership firm in taxable territory |
5 | Services by Central/State/UT Government/local authority to business entities excluding certain exempt services | Governments or local authorities | Business entities in taxable territory |
5A | Renting of immovable property by government entities to registered persons | Central/State/UT Government/local authority | Registered persons under CGST Act |
5AA | Renting residential dwelling to a registered person | Any person | Registered person |
5AB | Renting non-residential property by unregistered persons to registered persons, excluding composition scheme | Any unregistered person | Registered person (excluding composition scheme) |
5B | Transfer of development rights or Floor Space Index (FSI) to promoter | Any person | Promoter |
5C | Long term lease of land (30 years or more) for construction to promoter | Any person | Promoter |
6 | Services supplied by directors to company or body corporate | Director | Company or body corporate in taxable territory |
7 | Services by insurance agents to any person carrying on insurance business | Insurance agent | Insurance business entity in taxable territory |
8 | Services by recovery agents to banking companies, financial institutions, NBFCs | Recovery agent | Banks, financial institutions, NBFCs in taxable territory |
9 | Transfer or permitting use/enjoyment of copyright by music composer, photographer, artist to music company | Music composer, photographer, artist | Music company, producer in taxable territory |
9A | Similar copyright use/enjoyment by author to publisher, with forward charge options | Author | Publisher in taxable territory |
10 | Services by members of Overseeing Committee to Reserve Bank of India | Members of RBI Overseeing Committee | Reserve Bank of India |
11 | Services by individual Direct Selling Agents (DSAs) to banking or NBFC entities | Individual DSA (other than firm or body corporate) | Banks or NBFCs in taxable territory |
12 | Services by Business Facilitators to banking companies | Business facilitator | Banks in taxable territory |
13 | Services by agents of Business Correspondents to Business Correspondents | Agent of BC | BCs in taxable territory |
14 | Security services by supply of security personnel to registered person (with exclusions) | Any person other than body corporate | Registered person in taxable territory |
15 | Renting of motor vehicles to body corporate where provider opts 5% GST and is eligible for ITC | Any person other than body corporate (opted for 5%) | Body corporate in taxable territory |
16 | Lending securities under SEBI approved scheme | Lender | Borrower through approved intermediary |
This applies when a registered buyer purchases goods or services from an unregistered supplier but only for notified goods or services.
For example:
A registered real estate developer purchasing cement from an unregistered supplier must pay GST under reverse charge at the applicable rate of 28%
List of Supplies Under Section 9(4):
Sl. No. | Category of Supply | Recipient of Goods/Services |
1 | Goods and services (other than development rights, long-term lease of land, or FSI) constituting the shortfall from 75% minimum prescribed purchase value in a financial year | Promoter |
2 | Cement | Promoter |
3 | Capital goods | Promoter |
3. E-commerce Transactions
For specified services supplied through e-commerce platforms, the platform operator (not the individual supplier) is liable to pay tax. This simplifies tax collection in fragmented markets.
For example:
Cab rides booked via apps like Ola or Uber have GST paid by the platform operator under reverse charge, not the individual driver.
List of Specified Services Under Section 9(5), Where the Electronic Commerce Operator (ECO) is Liable to Pay GST:
S. No. | Description of Service | Supplier of Service | Person Liable to Pay GST |
i | Transportation of passengers by radio-taxi, motorcab, maxicab, motor cycle, or any other motor vehicle except omnibus | Taxi driver or rent-a-cab operator | Electronic commerce operator |
ia | Transportation of passengers by an omnibus | Any person except where supplied through ECO by a company | Electronic commerce operator |
ii | Providing accommodation in hotels, inns, guest houses, clubs, campsites, or other commercial lodging places | Any person except where supplied through ECO and liable for registration | Electronic commerce operator |
iii | Housekeeping services such as plumbing, carpentering, etc. | Any person except where supplied through ECO and liable for registration | Electronic commerce operator |
iv | Supply of restaurant services (other than those located at hotels with declared tariff above ₹7,500 per unit per day) | Any person | Electronic commerce operator |
Note: The list of goods and services covered under Reverse Charge Mechanism (RCM) is subject to periodic updates and changes based on government notifications and GST Council decisions. Businesses should stay informed about the latest notifications to ensure compliance.
Time of supply determines when tax liability arises. Under RCM, the recipient must ensure timely payment.
The time of supply is the earliest of:
If none can be determined, the date of book entry is taken.
The time of supply is the earliest of:
If none can be determined, the date of book entry is taken.
Mandatory Registration: Any person liable to pay tax under RCM must register under GST, even if their turnover is below the threshold.
Tax Payment: GST must be paid in cash (not through ITC) at the time of filing returns.
Self‑Invoicing: If the supplier is unregistered, the recipient must issue a self-invoice.
Payment Voucher: A payment voucher should also be issued when making payment to the supplier.
The recipient who pays GST under RCM is eligible to claim Input Tax Credit, provided:
The recipient cannot use ITC to pay the RCM tax itself, the tax under RCM must be paid in cash first. However, once paid, the recipient can claim the full ITC of this tax while filing GST returns.
Self‑invoicing is the process by which the recipient issues an invoice on behalf of the supplier. This is mainly required when the supplier is unregistered and thus cannot issue a GST invoice.
Self‑invoices should contain all the mandatory invoice details and must be maintained in the recipient’s books for GST compliance. This ensures the proper documentation of supplies liable to RCM and facilitates GST payment and claim of ITC.
Role | Return Form | Table | Purpose |
Recipient | GSTR-3B | Table 3.1(d) | Report RCM GST liability |
Recipient | GSTR-3B | Table 4(A)(3) | Claim ITC on RCM inward supplies |
Supplier | GSTR-1 | Table 4B (B2B RCM supplies) | Report outward supplies under RCM |
Ensure accurate reporting of RCM transactions in GST returns and maintain detailed records to support ITC claims and avoid compliance issues.