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Tuesday, September 19, 2017

Works Contract in GST regime - Certain directions by the Government of Tamil Nadu

WORKS CONTRACT IN GST REGIME IN TAMIL NADU



The Goods and Services Tax Act came into for with effect from 1.7.2017 in India.

In the VAT regime assessments were made on the deemed sale value of goods utilised in works contract besides levy of service tax with 60% abatement on new works and 30% abatement on repairs.  Compounding scheme option was also available in the earlier regime.

In the GST retime the works contract comes under services. There is no compound scheme of taxation for works contract in the GST regime.

Under the GST regime, GST (comprising CGST and SGST or IGST) on works contracts for Government work was initially notified at 18%.

The Central Government has announced reduction of GST from 18% to 12% with Input Tax Credit in respect of 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.

There are certain practical difficulties in making payments in respect of works contracts done by the contractors in the pre GST regime.

In order to complete the works which are in progress from the pre GST regime and post GST regime, the Government of Tamil Nadu has directed all government departments   and  procuring entities   shal make ‘on  account’  payment  o bills presented  by  contractors,   restricting  the payments  to  the value  due  as  per  existing  contract  agreements.  Any difference  on account of  finapayment due based on the guidelines to be issued and the ‘on  account payment made as above may be adjusted from out  of   the  5  percent amount retained  with the  procuring  entity.    The payment of  final  bill in cases where on account payments have been made shall be made only after the notification of the guidelines.

The Tamil Nadu Government’s G.O.Ms.No.264 Finance (Salaries) Department dated 15.9.2017 is given below for ready reference:




GOVERNMENT OF TAMIL NADU

FINANCE [Salaries] DEPARTMENT

G.O.Ms.No.264, Dated 15th September 2017. (Heyvilambi, Aavani-30, Thiruvalluvar Aandu 2048) ABSTRACT

Works Contracts - Payment in Works Contracts Consequent to Introduction of Goods and Service Tax - Orders-Issued.

Read:-

1 The Gazette of India Extraordinary No.12, dated: 12.04.2017.
2 The Gazette of India Extraordinary No.13, dated: 12.04.2017.
3 Tamil  Nadu   Governmen Gazett Extraordinary    No.189, dated: 23.06.2017.
-oOo-

ORDER:

The  Central  Goods  and  Services  (CGST Act  2017,  the  Integrated Goods and Services (IGST)  Act 2017 and the Tamil Nadu Goods and Services (TNGST)  Act 2017 have been enacted and enforced from 01.07.2017. Consequently, there has been a complete change in the indirect tax system in the Country and in the State of Tamil Nadu.

2. Certain difficulties  have arisen  on account of  this change of  tax regime in Government works contracts.  Typically, existing contracts  include clausestating that  risk arising due to change in law would be borne by procuring  entities.     However, it  ha been brought   to  notice  of   the Government that  existing works contracts  in  some  departments do  not provide for such a clause. Introduction of GST  is a major change in tax law. The Government has  therefore  taken  a  policy decision that  the  risk  on account  o change  otax  law  in  Government  works  contracts   due  to introduction   of    th GST     shal be  borne   by   th procuring   entity. The Government accordingly will  notify detailed guidelines for evaluating  the net change in tax liability on contracts  for the purpose of  payments to be made to the contractors and entering into supplementary agreements with contractors.

3. The Government  is also examining  the full implications of the GST on  works contract   and   government  procurement.     The  Public  Works Department  and  Highways Department  are  in  the  process  of   revising schedule  of  rates  to separate  out  taxes  subsumed  under  the  new GST regime from the schedule of rates.


4. In the meanwhile, it has come to the notice of the Government that bills  of existing contractors  are  being held up  ostensibly due  to lack of clarity on the treatment of GST. Delay in payment of bills for part  of works already executed by contractors is likely to result in locking of their working capitaand  slowing down of  works.   There have also been enquiries  and representations  from  contractors  on  non-payment  of   bills  presented by them,  apart  from   seeking  compensation  for  increased   tax  liability  on account of implementation of GST.

5. Under the new tax regime, GST  (comprising CGST, SGST and IGST) on works contracts for Government  work was initially notified at 18 percent. This had resulted in representations  from contractors of  ongoing works for compensation by procuring entity for increased tax liability over and above the contracted value of  work.   The difficulties arising out of  increased GST on works contracts for Government work was deliberated in the GST  Council Meetings held on 20th  August 2017 and 9th September 2017.  Consequently, the GS on  works contracts  for  Government  work is  being  reduced  t12 percent.   This move more or less balances the taxes on works contractin the pre GST  and post GST regime.

6. Pending notification  of  guidelines in the matter, the Government now  direct that   all  departments   and   procuring  entities   shal makon  account payment  obills  presented  by  contractors,   restricting  the payments  to the  value  due  as  per existing  contract  agreements.  Any difference  on account of  finapayment due based on the guidelines to be issued and the ‘on  account payment made as above may be adjusted from out  of   the  5  percent  amount  retained  with the  procuring entity.    The payment of final  bill in cases where on account payments have been made shall be made only after the notification of the guidelines.

(BY ORDER OF  THE GOVERNOR)



                                                                                    M.A. SIDDIQUE
                                                                                                         SECRETARY TO  GOVERNMENT (FAC)
To

All Secretaries to Government.
The Secretary, Legislative Assembly, Secretariat, Chennai-9.
The Comptroller, Governor's Household, Raj Bhavan, Chennai-32
The Governor's Secretariat,  Raj Bhavan, Guindy, Chennai-32.
All Heads of Department.
All Collectors / All District Judges / All Chief Judicial Magistrates. All Departments of Secretariat.
The Principal Accountant General(A&E), Chennai-18
The Accountant General (Audit-1), Chennai-35
The Accountant General (Audit-II), Chennai-6
The Accountant General (CAB), Chennai-9.
The Principal Secretary/Commissioner of Treasuries and Accounts, Chennai-15. All Pay and Accounts Officers/All Treasury Officers.
The Chairman,  Tamil Nadu Public Service Commission, Chennai-3
The Registrar, High Court, Chennai-104.
The Registrars of all Universities.
All State Owned Corporations and Statutory Boards. All State Public Sector Undertakings.
All Co-operative Federations
All Autonomous Bodies.
All Panchayat Unions / Municipalities / Town Panchayats.
The Commissioner, Corporations of Chennai /Madurai /Coimbatore / Tiruchirappalli / Salem / Tirunelveli / Erode / Tiruppur / Vellore / Thoothukudi.
Copy to:

The Senior Principal Private Secretary to the Additional Chief Secretary  to
Government, Finance Department, Chennai-9
All Sections in Finance Department, Chennai-9. 
Stock File  / Spare Copies.

-/ Forwarded : By Order /-

SECTION OFFICER











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