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Sunday, September 24, 2017

GST - Works Contract in GST Regime with tax rates for services and time of supply and place of supply

WORKS CONTRACT IN GST REGIME IN INDIA


The Goods and Services Tax Act, 2017 came into force in India with effect from 1.7.2017.



A house owner wants to paint the inner walls and outer walls of his own old house. For that purpose the house owner invites a mason and enquires about the same. 

The mason tells the house owner what are the materials needed and cost of the materials and also tells the amount of charges for undertaking that work.

1.The house owner purchases the materials needed for painting the house by purchasing the goods at his own risk and money and asks the mason to complete the painting work only with man power.

2.The house owner instead of purchasing the materials asks the mason to purchase the same and finish the work. The mason purchases the materials and completes the work of painting with man power and receives money for all.

In the first example the house owner supplies the goods and receives only man power service (which is called pure labour) from the mason.  This kind of transaction is called pure labour contract.

In the second example the house owner asks the mason to purchase the materials needed at the mason’s risk and money and after completion of work with the man power of the mason,   the house owner pays the amount for goods utilized for painting the walls and services rendered by the mason to paint the walls.  In this case both goods and services are supplied by the mason.   The mason undertakes the supply of goods which is called supply contract and also undertakes the supply of services which is called supply of services which is called services contract.

WHAT IS WORKS CONTRACT?

If the materials used for construction is supplied by a taxpayer at his business premises, the same will come under purview of supply of goods.  (Example: Sale of cement, sand, jelly, bricks, electrical goods and hardware items etc at the business premises by the building materials sellers.)

If the materials used for construction is supplied by a taxpayer and the same has been delivered by the taxpayer himself at the work spot premises, the same will come under the purview of composite supply.  (Example: Sale of cement, sand, jelly, bricks, electrical goods and hardware items etc by the taxpayer (seller) and delivery of the same through vehicle receiving freight charges, loading and unloading charges for services rendered from the recipient)

If another person other than the supplier of goods undertakes the supply of building materials at the work spot and receiving money for the goods supplied and for the services rendered the supplier of goods and services will be treated as Supplier of Goods and Services in other words “Contractor”. (Example: Purchases or procurement of cement, sand, jelly, bricks, electrical goods and hardware items etc by a person and supply of the same at the work spot through vehicle receiving cost of goods and supplied and transportation charges loading and unloading charges i.e. for the services rendered by him).

If the supplier of goods and services undertakes the construction of a house i.e. immovable property, the same will be called composite supply of Goods and Services which is called “Works Contract”.  (Example: A person purchases or procures cement, sand, jelly, bricks, electrical goods and hardware items etc and taking to the work spot and delivers in other form namely building, road, concrete mixture with utilization of labour for laying, constructing, leveling etc. and making the supplies as immovable properties.)

In simple, Works contract is a mixture of goods and services but it is neither a composite supply nor a mixed supply as it has been defined as per Section 2(119) of the Central Goods and Services Tax Act, 2017.

Section 2 (119):

“Works contract” means a contract for building, construction, fabrication, completion, erection, installation, fitting out, improvement, modification, repair, maintenance, renovation, alteration or commissioning of any immovable property wherein transfer of property in goods (whether as goods or in some other form) is involved in the execution of such contract.

Section 10 (2) (a) The registered person shall be eligible to opt under sub-section (1) if he is not engaged in the supply of services other than supplies referred to in clause (b) of Paragraph 6 of Schedule II (i.e. Restaurant services).

Section 17 (5) (c) works contract services when supplied for construction of an immovable property (other than plant and machinery) except where it is an input service for further supply of works contract service:

Section 17 (5) (d) goods or services or both received by a taxable person for construction of an immovable property (other than plant or machinery) on his own account including when such goods or services or both are used in the course of furtherance of business.

In the earlier tax regime Commercial Taxes Departments or Sales Tax Departments were levying tax at compounded rates or on the deemed sale value of goods utilized in works contract and the Central Government has levied Service Tax with 60% abatement on new works and 30% abatement on repairs.  The Commercial Taxes Department / Sales Tax Department has levied and collected VAT by following two methods:

1.Compounding Scheme at fixed percentage on total turnover; and

2.Non-compounding Regular Scheme which is based on the deemed sale value of transfer of property involved.

Under the Compounding Scheme the contractors undertaking works contract should pay certain percentage of tax on the total value of works contract and no input tax credit allowed.

Under non-compounding regular scheme the deemed sale value of goods arrived (i.e. transfer of property involved) and tax levied at the rates mentioned for goods in the schedules with input tax credit.

The verification of accounts and making assessments on works contractors comes under the purview of State Government for Goods and Central Government for Services in the earlier regime.  

In the GST Regime, works contract comes under Services and the assessing authority may be either Central Government or State Government as the case may be based on the turnover and place of supply.

Under GST Regime there is no compounding scheme of taxation.

Section 10(2)(a) of CGST Act further states that a person supplying services other than Restaurant services is not eligible to opt for composition scheme.

Compounding Scheme option is allowed only to Restaurant Services at 5% under services and no other services allowed compounding scheme in GST Regime.  Hence all works contractors will come under regular taxpayer scheme and have to pay tax at the rates mentioned in the schedules irrespective of turnover.

The following categories are exempt from GST.

1. Services provided by way of pure labour contracts of construction, erection, commissioning, installation, completion, fitting out, repair, maintenance, renovation, or alteration of a civil structure or any other original works pertaining to the beneficiary-led individual house construction or enhancement under the Housing for All (Urban) Mission or Pradhan Mantri Awas Yojana.

2. Services by way of pure labour contracts of construction, erection, commissioning, or installation of original works pertaining to a single residential unit otherwise than as a part of residential complex.

The following categories will attract 12% GST with no refund of accumulated input tax credit:

1.  Construction of a complex, building, civil structure or a part thereof, intended for sale to a buyer, wholly or partly (the value of land is deemed to be one-third of the total amount charged for such supplies).

The following categories will attract 18% GST with full Input Tax Credit:

1.  Composite supply of Works contract as defined in clause 119 of section 2 of CGST Act.

Reduction of GST from 18% to 12% with full ITC in certain cases:

1.  Works contract services provided to Government, local authority or governmental authority and in respect of post-harvest storage infrastructure for agricultural produce, mechanized food grain handling system.

REGISTRATION

Under Goods and Services Tax Act, 2017, separate registration in each State to be obtained.

Inter branch supply of goods / services are taxable.


PLACE OF SUPPLY

In the GST Regime, place of supply will play an important role.

Under Section 12 (2) (3) of the IGST Act, the place of supply of services (a) directly in relation to an immovable property, including services provided by architects, interior decoration, surveyors, engineers and other related experts or estate agents, any service provided by way of grant of rights to use immovable property or for carrying out or co-ordination of construction work shall be the location at which the immovable property or boat or vessels, as the case may be, is located or intended to be located. 

The place of supply for the supply of services in respect of immovable property-related services will be the location at which the immovable property is located. In such cases CGST and SGST will be applicable.

Where the immovable property or boat or vessel is located in more than one State or Union territory, the supply of services shall be treated as made in each of the respective States or Union territories, in proportion to the value for services separately collected or determined in terms of the contract or agreement entered into in this regard or, in the absence of such contract or agreement, on such other basis as may be prescribed.

No deduction shall be made if the location of the supplier and the place of supply is in a State or Union Territory which is different from the State or as the case may be, Union territory of registration of the recipient as per section 51(1)(d) proviso of the CGST Act,2017.

If the immovable property is located in more than one State, the supply of service shall be treated as made in each of the States in proportion to the value of the contract or agreement entered into in this regard or, in the absence of such contract or agreement, on such other reasonable basis as the case may be prescribed in this behalf as per the explanation clause to section 12(3) of the IGST Act, for domestic supplies.


TIME OF SUPPLY

In GST Regime, time of supply will also play an important role.

(a)   the date of issue of invoice by the supplier or the last date on which he is required, under sub-section (1) of section 31, to issue the invoice with respect to the supply; or

(b)  the date on which the supplier receives the payment with respect to the supply:

Provided that where the supplier of taxable goods receives an amount up to one thousand rupees in excess of the amount indicated in the tax invoice, the time of supply to the extent of such excess amount shall, at the option of the said supplier, be the date of issue of invoice in respect of such excess amount.

Explanation 1.––For the purposes of clauses (a) and (b), “supply” shall be deemed to have been made to the extent it is covered by the invoice or, as the case may be, the payment.

Explanation 2.––For the purposes of clause (b), “the date on which the supplier receives the payment” shall be the date on which the payment is entered in his books of account or the date on which the payment is credited to his bank account, whichever is earlier.

Period within which invoice has to be issued in a case involving continuous supply of services.

In case of continuous supply of services,

        Where the due date of payment is ascertainable from the contract, the invoice shall be issued on or before the due date of payment,

        Where the due date of payment is not ascertainable from the contract, the invoice shall be issued before or at the time when the supplier of service receives the payment,

        Where the payment is linked to the completion of an event, the invoice shall be issued on or before the date of completion of that event.

TAX DEDUCTION AT SOURCE IN GST REGIME

In the earlier VAT regime, Government Departments while making payments to the contractors for works done by them, Income Tax and VAT will be deducted at compounding rates. There may exemption to certain contractors who files monthly returns and paying tax on monthly turnover basis.

In the GST regime, under Section 51 (1) the Government may mandate (a) a department or establishment of Central Government or State Government or (b) local authority; or (c) Governmental agencies; or (d) such persons of category of persons as may be notified by the Government on the recommendations of the Council (hereafter in this section referred to as “the deductor”), to deduct tax at the rate of one per cent, from the payment made or credited to the supplier (hereafter in this section referred to as “the deductee”) of taxable goods or services or both, where the total value of such supply, under a contract, exceeds two lakhs and fifty thousand rupees:

No deduction shall be made if the location of the supplier and the place of supply is in a State or Union Territory which is different from the State or as the case may be, Union territory of registration of the recipient as per section 51(1)(d) proviso of the CGST Act,2017.

Explanation.––For the purpose of deduction of tax specified above, the value of supply shall be taken as the amount excluding the central tax, State tax, Union territory tax, integrated tax and cess indicated in the invoice.

(2) The amount deducted as tax under this section shall be paid to the Government by the deductor within ten days after the end of the month in which such deduction is made, in such manner as may be prescribed.

(3) The deductor shall furnish to the deductee a certificate mentioning therein the contract value, rate of deduction, amount deducted, amount paid to the Government and such other particulars in such manner as may be prescribed.

(4) If any deductor fails to furnish to the deductee the certificate, after deducting the tax at source, within five days of crediting the amount so deducted to the Government, the deductor shall pay, by way of a late fee, a sum of one hundred rupees per day from the day after the expiry of such five days period until the failure is rectified, subject to a maximum amount of five thousand rupees.

(5) The deductee shall claim credit, in his electronic cash ledger, of the tax deducted and reflected in the return of the deductor furnished under sub-section (3) of section 39, in such manner as may be prescribed.

(6) If any deductor fails to pay to the Government the amount deducted as tax under sub-section (1), he shall pay interest in accordance with the provisions of sub-section (1) of section 50, in addition to the amount of tax deducted.

(7) The determination of the amount in default under this section shall be made in the manner specified in section 73 or section 74.

(8) The refund to the deductor or the deductee arising on account of excess or erroneous deduction shall be dealt with in accordance with the provisions of section 54:

Provided that no refund to the deductor shall be granted, if the amount deducted has been credited to the electronic cash ledger of the deductee.

As per section 51, this provision is meant for Government and Government undertakings and other notified entities making contractual payments where total value of such supply under a contract exceeds Rs.2.5 Lakhs to suppliers. While making any payments under such contracts, the concerned Government/authority shall deduct 1% of the total payment made and remit it into the appropriate GST account.

DETAILS
RATE OF TAX
AND
MODE OF PAYMENT
Rate of tax for construction of a complex, building, civil structure or a part thereof, intended for sale to a buyer, wholly or partly (the value of land is deemed to be one-third of the total amount charged for such supplies).

12%
with no input tax credit
Rate of tax for composite supply of Works contract as defined in clause 119 of section 2 of CGST Act
18%
with full Input Tax Credit
Rate of tax for works contract services provided to Government, local authority or governmental authority and in respect of post-harvest storage infrastructure for agricultural produce, mechanized food grain handling system
12%
with full Input Tax Credit
in certain cases.
Rate of tax for services provided by way of pure labour contracts of construction, erection, commissioning, installation, completion, fitting out, repair, maintenance, renovation, or alteration of a civil structure or any other original works pertaining to the beneficiary-led individual house construction or enhancement under the Housing for All (Urban) Mission or Pradhan Mantri Awas Yojana
NIL
Rate of tax for services by way of pure labour contracts of construction, erection, commissioning, or installation of original works pertaining to a single residential unit otherwise than as a part of residential complex
NIL
Compounding Scheme for Works Contract
No compounding scheme allowed for works contract
Disclosure of turnover details to the Department
Monthly
Returns to be filed
GSTR-1 for outward supplies of goods and services
GSTR-2 for inward supplies of goods and services
GSTR-3 final return.

ITEM WISE RATE OF TAX FOR SERVICES UNDER GST


Click the link below to view the rate of tax for services item-wise.

https://cbec-gst.gov.in/pdf/central-tax-rate/Notification11-CGST-Annexure.pdf


Click the link below to view the works contract method of assessment in VAT regime
https://abhivirthi.blogspot.com/2016/03/works-contract-methods-and-types-of_29.html


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