RCM is not applicable in this case.
To understand the impact of GST on a Commission Agent, we first need to understand the concept of Pure Agent under GST Act.
Agent is a person who carries the business of supply of goods or services on behalf of another person (principal). Agent includes broker, commission agent, factor, auctioneer etc.
The fees charged by a Pure Agent can be broken down into:
Value of services provided by Agent to Principal. Eg: Commission, Brokerage, Agency fee etc.
Amount of reimbursement claimed by the Agent from the Principal for any expense incurred by him on behalf of the Principal.
The following factors need to be considered by a Commission Agent:
A Commission Agent is required to obtain Compulsory Registration irrespective of its turnover. Thus, the threshold limit of Rs.20 lakh does not apply to an Agent.
The benefit of Composition Scheme cannot be availed by an Agent since Composition Scheme is applicable only for supply of goods and not services.