Codes for recruitment work
The official SAC list places executive or retained personnel search at 998511, permanent placement other than executive search at 998512, and other employment and labour supply services at 998519. Monthly contract staffing is a different supply under 998513. All are under heading 9985 and taxed at 18%. A firm that both places permanent hires and deploys contract staff should keep them on separate invoices so the client's HR and procurement teams can track hiring cost and staffing cost apart.
Time of supply on joining
Placement fees are earned when the candidate joins. The invoice should be raised within 30 days of the service being completed, which in practice is the joining date. Agencies that wait for the replacement guarantee to expire before invoicing delay tax beyond the legal time limit. Invoice on joining, then use a credit note if the candidate leaves within the guarantee and a refund is due.
Credit notes for early exits
If a candidate resigns within the guarantee period and the agency refunds part of the fee, issue a credit note referring to the original invoice, reduce output tax in the return, and make sure the client reverses the matching input credit. The credit note must be issued by 30 November following the end of the financial year, or the return for that period, whichever is earlier. Replacements given free do not need a new invoice.
Recruiting for foreign employers
An Indian agency sourcing candidates for a Gulf or European employer may be exporting services if the employer is located abroad and pays in foreign exchange. Charging fees to candidates rather than employers is a different supply, taxable in India, and is also restricted by emigration rules for overseas recruitment, which require registration as a recruiting agent.
Job portals and advertisements
Agencies often buy job portal subscriptions and job ads. These carry 18% GST from the portal and can be claimed as input credit. Recharging them to the client as part of the fee keeps the whole amount at 18% under your own SAC.
Campus and bulk hiring drives
Agencies that run campus drives or bulk hiring for call centres and retail chains often charge a flat fee per drive or per batch rather than a percentage of CTC. These belong under 998519, other employment and labour supply services, at 18%, and the invoice should describe the drive, the institution or location, the dates and the number of candidates assessed and selected. When a drive fee is followed by per-hire fees for the candidates who join, keep the two as separate lines, because the drive fee is earned on completion of the drive whether or not anyone joins, while per-hire fees follow the joining dates.