No Indian e-invoice or IRN is required for an import of services. The Indian recipient that is liable to pay GST under reverse charge handles the tax invoice, IGST payment and GST-return reporting. The overseas supplier does not create an Indian IRP e-invoice, and the recipient must not upload the imported-service document to the IRP merely because the recipient crosses an e-invoicing turnover threshold.
The rule in one view
Indian e-invoicing is a supplier-side authentication system for specified domestic business documents. Imported services are outside that mandate. The IRP FAQ expressly says that where supplies are received from an unregistered person or through import of services, e-invoicing is not applicable. It also says an e-invoice can be generated only by the supplier; a recipient or transporter cannot generate one.
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For a cross-border service, the practical responsibility therefore moves to the Indian recipient when the transaction is taxable in India under reverse charge. The recipient determines whether reverse charge applies, issues the required recipient invoice or self-invoice, pays IGST, reports the liability in the GST return and claims eligible input tax credit through the normal reverse-charge process. The foreign vendor’s commercial invoice remains supporting documentation, not an Indian IRN document.
Why an imported service is not an IRP e-invoice transaction
Import status controls the result
A service is treated as an import only after checking the supplier’s location, the recipient’s location and the place-of-supply rules. The supplier must be outside India, the recipient must be in India, and the place of supply must ordinarily be in India under the applicable Integrated GST rules. Special place-of-supply provisions can change the result for particular services, so do not classify a transaction from the vendor’s country alone.
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Once the transaction is an import of services, the IRP exclusion applies even when the Indian recipient is a notified e-invoice taxpayer. A high annual aggregate turnover does not override the import exclusion. Keep the foreign supplier invoice, contract, service-delivery evidence and payment records so the classification can be demonstrated during an audit.
The foreign supplier does not create an Indian IRN
The overseas supplier generally has no Indian IRP access or Indian e-invoice obligation for the imported service. More importantly, the IRP system is designed for the supplier that issues a covered invoice. A recipient cannot solve the issue by logging in and generating an IRN on the vendor’s behalf. The correct document trail is the supplier’s commercial invoice plus the Indian recipient’s reverse-charge documentation where required.
Who raises the invoice under reverse charge?
Recipient responsibility
Under the reverse-charge mechanism, the legal liability to pay GST shifts from the supplier to the recipient. A registered Indian recipient liable under reverse charge must issue the invoice for services received from an unregistered supplier when the recipient-invoice rule applies. For an import of services, that means the Indian entity—not the foreign vendor—controls the GST invoice and tax-payment workflow.
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Invoice date versus tax date
Do not treat the date on the recipient invoice as automatically determining the GST liability. GST law separates the obligation to issue an invoice from the time of supply used to calculate when reverse-charge tax becomes payable. Your accounting procedure should record both dates and the rule used for each.
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When should the recipient issue the reverse-charge invoice?
Receipt-of-service trigger
Section 31(3)(f) of the CGST framework, read with the corresponding IGST application, requires a registered person liable under reverse charge to issue an invoice for services received from an unregistered supplier where that rule applies. Operationally, issue the recipient invoice on the date the service is received. Define “received” in your records using an objective event such as acceptance of the deliverable, completion of the contracted period or another documented service-acceptance milestone.
For recurring services, document whether each monthly or milestone delivery is a separate receipt. A single year-end entry can create a timing problem if the services were actually received earlier. Match the invoice date to the receipt evidence and retain the foreign invoice and contract terms that support the date.
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The 30-day Rule 47 period
Rule 47 provides a 30-day period for issuing an invoice for a taxable service; the CBIC rules amendment cited for this period took effect on 1 January 2022. That is an invoice-issuance rule for the relevant taxable service. It is not an IRN-generation deadline for imported services. Because imports of services are outside e-invoicing, neither the 30-day period nor the recipient’s turnover creates an IRP reporting requirement.
When does reverse-charge IGST become payable?
Ordinary foreign supplier
For reverse-charge services, the CBIC sectoral FAQ describes time of supply as the earlier of:
- the date the recipient records or debits payment to the foreign supplier; or
- the date immediately following 60 days from the date of the foreign supplier’s invoice.
The 60-day point is an outer trigger in the time-of-supply calculation. It does not mean the recipient can postpone all documentation for 60 days. Issue the recipient invoice when the service is received under the applicable invoice rule, then use the statutory time-of-supply test to place the IGST liability in the correct return period.
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Overseas associated enterprise
There is a specific exception for services received from an overseas associated enterprise. The earlier of the date the recipient enters the transaction in its books or the date of payment controls the time of supply. The 60-day calculation used for an ordinary foreign supplier should not be substituted for this associated-enterprise test.
Maintain a related-party determination, the book-entry date and payment date in the tax file. If the book entry precedes payment, the earlier book-entry date drives the liability.
How to report and pay the tax in GST returns
Pay the reverse-charge liability
Calculate IGST using the applicable valuation and rate for the service. Reverse-charge tax must be paid through the GST return process; it is not settled by obtaining an IRN. Confirm the place of supply, valuation, rate and any exemption before posting the liability because those outcomes depend on the exact service and facts.
Report the liability in GSTR-3B
Use the current GSTR-3B instructions and the tax-liability table applicable to reverse-charge inward supplies for the period. GSTN separately confirms that reverse-charge credit on import of services is not included in GSTR-2B and continues to be entered by taxpayers in Table 4(A)(2) of GSTR-3B. In practice, the return workflow has two linked entries:
- declare and pay the reverse-charge IGST in the appropriate tax-liability section; and
- record eligible input tax credit for that paid reverse-charge tax in Table 4(A)(2), subject to the normal credit conditions.
Do not wait for a foreign supplier’s invoice to appear in GSTR-2B. Imported-service reverse charge is a recipient-reported item, so reconcile it to the recipient invoice, payment evidence and accounting ledger instead.
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Recipient workflow: a control-ready sequence
- Classify the supply. Confirm that the supplier is outside India, the recipient is in India and the place-of-supply rules make it an import of services. Record the service category and the reasoning.
- Test reverse-charge liability. Check the current IGST notifications, exemptions and any sector-specific rule. Identify the Indian registered person responsible for payment.
- Capture the commercial evidence. Store the foreign supplier invoice, contract, statement of work, acceptance or completion evidence, currency conversion support and payment trail.
- Determine the time of supply. For an ordinary foreign supplier, compare the payment date with the date immediately after 60 days from the supplier invoice. For an overseas associated enterprise, compare book-entry and payment dates.
- Issue the recipient invoice. Where the recipient-invoice rule applies, issue it on receipt of the service and mark the transaction as reverse charge. Do not create an IRN.
- Compute IGST. Apply the correct taxable value, rate and place-of-supply treatment. Preserve the calculation and the exchange-rate source used for the accounting entry.
- File and pay. Report the reverse-charge liability in the applicable GSTR-3B tax-liability table and pay it in cash as required by the return rules.
- Record eligible credit. After satisfying input-tax-credit conditions, enter the import-of-services reverse-charge credit in Table 4(A)(2) of GSTR-3B. Do not expect a corresponding GSTR-2B line.
- Reconcile monthly. Match the vendor invoice, recipient invoice, time-of-supply date, payment, ledger, GSTR-3B liability and credit. Investigate unmatched items before filing the next return.
Domestic reverse charge versus imported services
| Control point | Ordinary domestic reverse-charge supply | Imported service |
|---|---|---|
| IRP e-invoice | Depends on whether the transaction and issuing supplier are within the e-invoice mandate; reverse charge alone does not answer the question. | Not applicable. Import of services is excluded from e-invoicing, so no IRN is generated. |
| Who issues the invoice | The supplier issues an invoice where the supplier is required to do so; the recipient may issue a reverse-charge invoice where the recipient-invoice rule applies. | The Indian recipient liable under reverse charge issues the required recipient invoice where applicable and retains the foreign supplier’s commercial invoice. |
| Time-of-supply trigger | Use the rule applicable to the specified domestic reverse-charge category. | Ordinary foreign supplier: earlier of payment recorded or the day after 60 days from the supplier invoice. Overseas associated enterprise: earlier of book entry or payment. |
| Return and payment | Report and pay according to the domestic reverse-charge tables and current return instructions. | Pay reverse-charge IGST through GSTR-3B; eligible credit for import-of-services reverse charge is entered in Table 4(A)(2), not received through GSTR-2B. |
| Evidence to retain | Supplier status, notification coverage, invoice, receipt and payment records. | Supplier location, place-of-supply analysis, foreign invoice, contract, service receipt, payment, book-entry date for associated enterprises and recipient invoice. |
Turnover thresholds and the 30-day IRP restriction
The IRP mandate has expanded over time: the stated aggregate annual turnover thresholds were ₹500 crore from 1 October 2020, ₹100 crore from 1 January 2021, ₹50 crore from 1 April 2021, ₹20 crore from 1 April 2022, ₹10 crore from 1 October 2022 and ₹5 crore from 1 August 2023. The ₹5 crore threshold is the general context for taxpayers brought into the mandate from 1 August 2023.
These thresholds determine whether a taxpayer is generally covered for specified e-invoice documents. They do not convert an imported service into an IRP transaction. A recipient with ₹5 crore, ₹10 crore or higher turnover still does not obtain an IRN for an imported service solely because of turnover.
From 1 April 2025, the IRP also records a 30-day reporting restriction for covered e-invoices issued by taxpayers with aggregate annual turnover of ₹10 crore or more. That restriction applies to documents that are otherwise within the e-invoice mandate. It is not a 30-day IRN deadline for imported services, which remain outside the mandate.
Common mistakes and how to correct them
Uploading the foreign invoice to the IRP
Problem: The recipient assumes every cross-border invoice needs an IRN. Correction: classify the transaction as an import of services and keep the commercial invoice and recipient invoice in the tax file; do not upload it to the IRP.
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Problem: The accounts team delays reverse-charge credit because no supplier document appears in GSTR-2B. Correction: GSTN excludes import-of-services reverse-charge credit from GSTR-2B. Reconcile the credit to the recipient’s own records and enter eligible credit in Table 4(A)(2).
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Using the wrong time-of-supply rule
Problem: Staff apply the 60-day test to an overseas associated enterprise. Correction: for an associated enterprise, compare book-entry and payment dates; for an ordinary foreign supplier, apply the payment-versus-60-day test.
Confusing invoice timing with tax timing
Problem: The recipient postpones issuing its invoice until payment or treats the invoice date as the only tax trigger. Correction: document service receipt for the recipient-invoice requirement, then separately calculate the statutory time of supply.
Assuming every foreign service is taxable in India
Problem: Reverse charge is posted without checking place of supply, valuation, rate or exemption. Correction: perform a transaction-specific IGST analysis and retain the conclusion with the contract and service description.
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- Foreign supplier legal name, address and evidence of location outside India.
- Contract, purchase order or statement of work describing the service.
- Foreign supplier invoice number, date, currency and value.
- Evidence of receipt, acceptance or completion of the service.
- Place-of-supply analysis and the reason the transaction is an import of services.
- Reverse-charge notification, exemption and tax-rate assessment.
- Recipient invoice date and number, including reverse-charge notation.
- Payment date, bank advice and exchange-rate calculation.
- For associated enterprises, the book-entry date and relationship documentation.
- GSTR-3B liability, payment reference and Table 4(A)(2) credit entry.
What can change the answer
Reverse-charge applicability, place of supply, valuation, rate, exemptions and input-tax-credit eligibility depend on the service and the parties’ facts. GST notifications, IRP coverage and return instructions can change. Recheck the latest CBIC and GSTN instructions before filing, especially when a service category, related-party relationship or reporting threshold is unusual.
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