GOODS AND SERVICE TAX IN INDIA All rights reserved | Preliminary & Tentative OVERVIEW | IMPLEMENTATION CHALLENGES Rajeev Dimri | Partner GST – Why so much noise… • Most significant indirect tax reform in Indian history • Stakeholders - Government, business community as well as common man • Tax administration system will undergo significant functional change • Will make indirect tax environment more simple, stable and predictable (hopefully!) 3 | GST: IMPLEMENTATION CHALLENGES All rights reserved | Preliminary & Tentative • Will impact each commercial / business activity Taxes to be subsumed under GST Central Levies State Levies Excise Duties including the additional excise duties VAT/ Sales tax Cesses in the nature of excise duty /customs duty CST to be abolished Entertainment tax (unless levied by the local bodies) Subsumation of taxes Taxes on lottery, betting and gambling Service tax Cesses and surcharges levied by Union ie education cess etc Luxury tax Purchase tax to be subsumed Cesses and surcharges levied by States, related to supply of goods and services • Municipal levies - likely to be out Central GST 3 | GST: IMPLEMENTATION CHALLENGES • Stamp duty - likely to be out State GST All rights reserved | Preliminary & Tentative Additional duties of customs (ie CVD and ACD) Entry tax not in lieu of octroi Overview of the new landscape KEY GST CONCEPTS Taxable event to be ‘supply’ Place of supply Exemptions Destination based tax Valuation Rules for services? States to levy tax on services Multiplicity of taxes GST to subsume most current indirect taxes Credit To be replaced by CGST and SGST, IGST and additional tax on inter-state supply Possible expansion of credit base Credit pool to be maintained for each state 6 | Likely to be consistent for all goods and services – MRP valuation may go GST: IMPLEMENTATION CHALLENGES Classification Likely to either be withdrawn or be converted into refund mechanism Rates Tax rates to change for inputs and outputs Initially 1% additional tax on inter-state sales All rights reserved | Preliminary & Tentative Taxable event All rights reserved | Preliminary & Tentative GST – KEY IMPLEMENATION CHALLENGES Paradigm shift Determining consumption state Determining origin state (to levy additional tax) Taxability of inter-unit transfers 6 | GST: IMPLEMENTATION CHALLENGES Supply based taxation Taxation of imports All rights reserved | Preliminary & Tentative Taxing jurisdiction in case of chain transactions Job-work / tolling arrangements Crafting a workable design Need for a pragmatic and business friendly approach Place of supply rules – special focus needed for service sector GST rates – difference in SGST rates likely to pose immense challenge (refer next slide) Defining valuation principles – need to ensure non repeating FIAT like experience Defining flexibility norms for states regarding tax rates, exemptions, compliances etc 7 | GST: IMPLEMENTATION CHALLENGES All rights reserved | Preliminary & Tentative Determining taxable threshold – 10 lac v 25 lac (significant impact on tax paying base!) Crafting a workable design Need for a pragmatic and business friendly approach Characterization of borderline transactions (eg works contracts, intangibles, lease, software) Synchronization with foreign trade benefits Need for simplified taxation structures for very small & large tax payers Taxation of key strategic / evolving sectors – eg real estate, ecommerce, telecom 8 | GST: IMPLEMENTATION CHALLENGES All rights reserved | Preliminary & Tentative Special regimes – SEZ, EOU’s, Area based exemptions Difference in SGST rates – likely challenges Jurisdiction disputes Distortion of trade SGST rate Tax driven supply chain planning to continue Multitude of audits, investigation s May impact port of import decisions 9 | GST: IMPLEMENTATION CHALLENGES All rights reserved | Preliminary & Tentative Customer state wise SGST rates for billing purposes Transitional challenges Phased transition • Some products / sectors (petroleum, liquor) may be kept outside to begin with Fate of investment linked incentives Transition of opening credits • Tax credits pertaining to the present indirect tax regime will require seamless transition Additional tax • Credit eligibility • Applicability on imports 10 | GST: IMPLEMENTATION CHALLENGES All rights reserved | Preliminary & Tentative • Whether the investment linked indirect tax benefits presently extended by several states would be continued under the proposed GST regime? Admin and infrastructural preparedness • Training needs • Defining procedures and processes 11 | GST: IMPLEMENTATION CHALLENGES Systems • Alignment with the new levy • Proper upkeep and maintenance Network • Real time coordination between various stakeholders All rights reserved | Preliminary & Tentative Personnel Likely challenges to enforcement agencies Managing risk of GST fraud Role of customs authorities Key challenges Taxation of services by States Robust GSTN and online compliances Coordination between state & central departments 12 | GST: IMPLEMENTATION CHALLENGES All rights reserved | Preliminary & Tentative Training needs Likely challenges for tax payers A new tax law – a whole lot of tax controversies Transaction restructuring Procurement pattern and trading models to be analysed – No significant difference between local and interstate under GST? Billing patterns, local vis-à-vis inter state to be reviewed Costing / Pricing of goods Transition of credits New registrations Overall pricing of goods – factoring of GST credits Change in contract clauses Change in rate of taxes Review of procurement costs Taxability of transactions spread across regimes Treatment of tax paid inventory Records/ Accounting State-wise sales records Credit availment and utilization records 13 | GST: IMPLEMENTATION CHALLENGES Re-designing of the entire ERP Current ERP is aligned as per the current taxes Compliance Tax computations New formats for invoices / records/ returns/ declarations Validity of statutory form (Form F/Form C) Change in accounting Manner of payment of taxes Re-defining the logics New compliance dates Updating masters Documentation for movement of goods All rights reserved | Preliminary & Tentative Transaction structuring to be reviewed Transition BMR’s take With current level of preparedness April’16 timeline looks a daunting task A well planned and coordinated approach between policy makers, enforcement agencies and industry critical to achieve the timeline Urgent need to roll out high-level design of the new law for deliberations by stakeholders GST the need of the hour to combat the globally so perceived ‘tax terrorism’ in India! 13 | GST: IMPLEMENTATION CHALLENGES All rights reserved | Preliminary & Tentative However, with increasing global focus on India as investment base market, no room for postponing this critical indirect tax reform Disclaimer Purpose of this presentation is to give a highlights of the proposed GST regime in India and not render any definitive opinion on any of the activities of stakeholders under the GST regime Prior professional advise is advised before implementation of aspects covered under this presentation Some of the features highlighted including the IGST model for interstate supplies are understood to be under reconsideration It is likely that the final model would differ from our understanding and the implications discussed herein would accordingly vary and the contents of this presentation would need to be updated basis the revised GST frame-work in the offing BMR is under no obligation to update this presentation for future changes 15 | OVERVIEW & IMPLEMENTATION OF GST All rights reserved | Preliminary & Tentative Our comments in the preceding slides are based on the GST framework outlined in the First Discussion Paper on GST (2009) and the Constitution Amendment Bill, 2014