RCM on Renting of commercial property applicability date.

Final Notification from CBIC is awaited....

Notification 09/2024-CTR is effective 10 October 2024. This is the exact date from which RCM applies on renting of commercial property from unregistered persons to registered persons.

For rent paid before 10 October 2024: no RCM was applicable (old rule did not cover commercial property from unregistered persons). No retrospective liability.

For rent paid from 10 October 2024 onwards: if your landlord is unregistered and you are GST registered, you must pay 18% GST under RCM. If you have been paying rent from October 2024 without paying RCM, you now have a liability for that period including interest at 18% per annum.

How to regularize past liability:
- Compute the GST on commercial rent for October 2024 onwards
- Pay the tax in cash via GSTR-3B for the current month (declare it in Table 3.1(d) as RCM inward supplies)
- Interest is due for past months; voluntary payment reduces the risk of penalty
- No penalty if the omission was due to genuine confusion about the notification date, but you need to proactively pay before receiving a notice

For the full RCM compliance process for commercial rent including how to report in GSTR-3B, this [GST on rent guide for commercial and residential property](https://taxgarden.in/blog/gst-on-rent-commercial-residential-rcm-itc-guide) has the reporting walkthrough.