The e-invoicing extension the GST Council recommended on 8 October has started to become machinery. One of its two new supply types, RCMIMP, lands squarely on every Indian subsidiary that receives services from its own group abroad.
When India's GST Council met on 8 October it recommended extending e-invoicing to reverse-charge purchases, including imported services. Eight days later GSTN opened sandbox testing for the two supply types that will carry it: RCMDOM for domestic purchases from unregistered suppliers, and RCMIMP for services received from outside India.
The second one is the one that reaches you.
What RCMIMP actually is
When an Indian entity receives a service from a supplier outside India, the foreign supplier charges no Indian tax. The Indian recipient accounts for IGST itself under reverse charge, and — because no Indian invoice exists — it also raises the invoice, to itself. That document is a self-invoice.
RCMIMP is the supply type under which that self-invoice will be reported to India's Invoice Registration Portal to obtain an IRN, in the same way a domestic sales invoice already is.
Who in your group this lands on
The Indian entity, not you.
This is worth being precise about, because the instinct in a group head office is to ask what the parent must now issue. The answer is nothing. The obligation sits with the Indian recipient: it raises the self-invoice, it reports it, it pays the IGST, it claims the credit.
What changes for the parent is that the Indian entity's ability to discharge that obligation on time now depends on information the parent controls — principally when the charge is raised and what it is for.
The charges it catches
Anything your group bills into India that is a service. In practice:
- Management and head-office charges
- Software licences, SaaS and cloud subscriptions
- Technical, professional and consultancy services
- Group IT, shared-service and support recharges
- Cost allocations where the substance is a service
- Advertising platforms billing from outside India
What it does not touch
- Import of goods. IGST on goods is paid on the bill of entry at customs. Different mechanism, unaffected.
- Services from a supplier registered in India. That supplier issues its own invoice, so no self-invoice arises.
The thirty-day clock most groups have not noticed
This is where the operational problem sits, and it predates the advisory.
The self-invoice is not new. India's section 31(3)(f) has always required the recipient to raise it. Since 1 November 2024, rule 47A has required it within 30 days of receiving the service.
Intra-group charges rarely move at that speed. Management fees are often settled quarterly, cost allocations annually, and a true-up can arrive months after the period it relates to. If the service was received in April and the recharge is raised in September, the Indian entity's thirty days expired long before the paperwork arrived.
Today that mismatch is buried in the ledgers. Once each self-invoice carries an IRN and a date, the gap between when a service was received and when it was documented becomes a reportable fact.
What this is not, yet
It is not law. GSTN has opened the facility in the sandbox — the test environment of all six Invoice Registration Portals — and has said the production date and the start of the reporting requirement will be communicated separately. Scope and timing will come from the notification that follows.
The stated threshold is aggregate annual turnover of Rs 5 crore and above, which matches India's existing e-invoicing threshold. That is roughly GBP 450,000 or USD 600,000 of Indian turnover: low enough that a modest Indian subsidiary clears it comfortably.
What to do now
- Establish whether your Indian entity's aggregate turnover has crossed Rs 5 crore in any year since 2017-18. If it has, assume RCMIMP will apply.
- List every recurring charge your group raises into India and the frequency at which it is raised. Anything billed less often than monthly needs examining against the thirty-day rule.
- Ask the Indian finance team to reconcile reverse-charge IGST paid in the last twelve months against self-invoices actually raised. A gap there is a present exposure, not a future one.
- Check foreign card-paid subscriptions bought locally by the Indian entity. No supplier invoice reaches accounts, so these are the ones most often undocumented.
- Change nothing in filings yet. Liability, time of supply, payment and credit are untouched; only the reporting of the self-invoice is in question.
The wider point
The 57th Council's recommendations read as policy. This is the first of them to appear as plumbing, eight days later, and the pattern is worth noting: the Council proposes, GSTN builds, and the notification arrives afterwards to make it binding. Groups that treat the sandbox as the signal have months to prepare. Groups that wait for the notification will have weeks.
Alverian advises on cross-border structuring and indirect tax across jurisdictions, drawing on R. K. Chari & Co. for India chartered-accountancy work — see tax and legal services and our note on what the 57th Council changed for cross-border groups.