Code and rate
The official SAC list codes insolvency and receivership services at 998240 under heading 9982, legal and accounting services. The rate notification taxes this heading at 18%, and the September 2025 changes left it untouched. Insolvency professional entities and individual IPs use the same code.
Who is the recipient
During CIRP the IP bills the corporate debtor, now managed by the IP, for professional fees approved by the committee of creditors. The corporate debtor's GSTIN is used on the invoice, and the debtor may claim credit if eligible. Where the IP is engaged by a creditor or applicant before appointment, such as for advisory, the creditor is the recipient.
CIRP costs from other professionals
Valuers, legal advisors and security agencies appointed during CIRP bill the corporate debtor directly for their services at their own rates and codes. The IP should not route those fees through its own invoice, or they become part of its supply at 18% and may confuse the CoC's cost tracking.
Liquidation
In liquidation, the liquidator's fee is decided as per the regulations or by the CoC, and is paid out of the liquidation estate. The invoice is raised on the corporate debtor in liquidation. Sales of the debtor's assets by the liquidator are supplies by the corporate debtor with their own GST implications, separate from the liquidator's fee.
Monthly billing
Bill monthly on the date set in the CoC resolution, with the period on the invoice. Advance fees, if any, are taxed when received through a receipt voucher.
Corporate debtor's GST compliance
Once appointed, the IRP or RP manages the corporate debtor's affairs, which includes its GST compliance during CIRP: filing returns, issuing invoices for supplies the debtor continues to make, and dealing with pending notices. CBIC has issued a special procedure for corporate debtors under CIRP, and the IP should check the current version on the CBIC site before deciding which registration to use for the debtor's supplies and for its own fee invoices. Whatever the registration position, keep the IP's own fee invoices, raised under the IP's GSTIN, distinct from invoices the debtor issues to its customers, since mixing them makes the CoC's review of resolution costs much harder.
Fees approved by the committee of creditors
Insolvency regulations require the IP's fee to be fixed by the committee of creditors, and creditors scrutinise every payment out of the CIRP fund. An invoice that mirrors the CoC resolution is approved quickly; one that differs is queried. State the fee approved, the resolution date and meeting number, the period the invoice covers, and any performance-linked component and how it was calculated. Where the CoC approves fees in stages, such as a monthly fee plus a success fee on approval of a resolution plan, bill each stage as its own line when it falls due, with GST at 18% on each, so the CoC can track total resolution costs against the budget it set.