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Tuesday, October 3, 2017

Reverse Charge Mechanism under GST with applicable and not- applicable details with time of supply and ITC adjustments

REVERSE CHARGE MECHANISM UNDER GST

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

  



In the earlier tax regime, a dealer who purchases any goods which are liable for taxation from a registered dealer (without sufferance of tax) or from any other person and consumes or uses such goods in or for the manufacture of other goods for sale or otherwise or disposes of such goods in any manner other than by way of sale in the state or despatches or carries them to a place outside the State except as a direct result of sale or purchase in the course of inter-State trade or commerce or in the course of export out of the territory of India or installs and uses such goods in the factory for the manufacture of any goods shall pay tax on the turnover relating to the purchase at the rates specified in the schedules.

The dealers effected purchases as shown above and disclosed the same as purchases from unregistered dealers and paid purchase tax at the rates mentioned in the schedules in the earlier tax laws. It is easy to understand that purchase tax paid on purchases effected from unregistered person or purchases effected without sufferance of tax at earlier stage is called Reverse Charge Mechanism under the Goods and Services Tax Act, 2017 which is applicable for services also.

In the GST regime, purchases and sales were defined as inward supply and outward supply. In the GST regime unregistered supplier means supplier of goods or supplier of services or supplier of both.

GST is a destination based tax on consumption of goods or services or both.

In India, the concept of reverse charge under GST is being introduced which already present in service tax. 

Reverse charge under GST may be applicable for both services as well as goods.

The goods or services received from the unregistered suppliers and the tax payable thereon were defined as Reverse Charge Mechanism under the Goods and Services Tax Act, 2017.  Reverse charge mechanism will apply both for goods and services.

Under the Goods and Services Tax Act, 2017 if the goods were not suffered tax at earlier stage Reverse charge Mechanism will be applicable.

Reverse charge means the liability to pay tax is by person receiving goods and/or services instead of the person supplying the goods and/or services in respect of specified categories of supplies. 

All persons who are required to pay tax under reverse charge have to register for GST irrespective of the threshold under Section 24 of the CGST Act 2017.

Reverse Charge under GST:

As per Section 2 (98) of CGST Act 2017:
  • the liability to pay tax by the recipient of supply of goods or services or both
  • instead of the supplier of such goods or services
Under Reverse charge liability to pay tax is on the recipient of goods/services instead of the supplier. Reverse charge may be applicable for both services as well as goods.
Reverse Charge Mechanism is applicable in all cases of supply from Unregistered Dealer to Registered Dealer under Section 9(4)
and

Reverse Charge Mechanism is applicable in all cases of supply of specified goods and Services which are notified by the Government under Section 9(3),

Reverse Charge Mechanism is applicable only for supply of goods or services or both within the State by unregistered persons. 

Without GSTIN a supplier of goods or services cannot supply goods or services to another person located outside the state.  The provisions of Reverse Charge will not be applicable to inter-State supplies received, as the inter-State supplies cannot be made by unregistered suppliers.  Similarly suppliers who opted to pay tax under compounded scheme cannot supply goods or services to the recipients outside the state.

Reverse Charge Mechanism will not be applicable between two regular taxable persons registered under the Goods and Services Tax Act, 2017 and the same will apply for the purchases effected from the Compounding Scheme opted suppliers

If a regular taxable person effect purchases of goods or services from a compounding scheme taxable person Reverse Charge Mechanism will be applicable. 

Similarly if a Composition Scheme registered person effects purchases of goods or services from unregistered persons, Reverse Charge Mechanism will be applicable

Reverse Charge provisions would not be applicable if the aggregate value of supplies of goods or services or both received by a taxable person from unregistered supplier does not exceed Rs. 5000.00 in a day.

The Central Government has specified that the persons who are only engaged in making supplies of taxable goods or services or both, the total tax on which is liable to be paid on reverse charge basis by the recipient of such goods or services or both under sub-section (3) of section 9 of the said Act as the category of persons exempted from obtaining registration under the GST Act, 2017.

The tax payable under Reverse Charge Mechanism should be paid by E-payment or other modes separately without adjustment from the available Input Tax Credit.  The tax payable under Reverse Charge Mechanism should be paid fully for each month separately and no partial payment allowed.

Reverse Charge Mechanism will not be applicable for the following categories

·       Allowance to employees
·       Bad Debts
·       Bank interest
·       Bonus paid to employees
·       Conveyance Expenses by non A/c Auto Fare
·       Conveyance Expenses by non A/c Bus Fare
·       Conveyance Expenses by non A/c Taxi Fare
·       Conveyance Expenses by non A/c Train Fare
·       Corporation tax
·       Depreciation
·       Diesel Expenses
·       Discounts shown in bill
·       Donations
·       Electricity Charges
·       Exempted Goods
·       Exempted Services
·       Fines
·       Free Gifts to Customers / Free Gifts: Gold Coin to Customers
·       Gifts to Staff upto Rs. 50000.00 by an Employer
·       Godown Rent for Agricultural Produce
·       Incentive to Employees
·       Interest on Service Tax
·       Interest on TDS
·       Interest on Vehicle Loan
·     Intra-State supplies of goods or services or both received by a registered person from any supplier, who is not registered, from the whole of the central tax leviable there on where the aggregate value of such supplies of goods or services or both received by a registered person from any or all the suppliers, who is or are not registered
·       Kerosene
·       Labour Welfare Contributions
·       Licence Renewal fees for Boilers
·       Licence Renewal fees for Factories
·       Licence renewal fees for Local Bodies
·       License renewal fees for Pollution control
·       Loading and Unloading expenses for agricultural products
·       Local conveyance
·       Municipal tax
·       News Papers and Magazines
·   Old and used empty bottles buying and selling by a registered taxable person under margin scheme
·       Other Deposits
·       Other interest
·       Penalties
·       Petrol expenses
·       Profession tax
·    Purchases of taxable goods / services upto Rs.5000.00 per day from unregistered suppliers
·       Registration Fees
·       Remuneration
·       Rent Deposits
·       Residential House / Flat Rents
·       Salary paid to Employees
·       Sale of old gold jewellery by an individual to a jeweller
·    Second hand goods buying and selling by a registered taxable person under margin scheme
·       Staff Medical Claim Contribution
·       Wages paid to Employees
·       Warranty Labour charges
·       Water charges


Reverse Charge Mechanism will be applicable for the following categories including 15 services

·    Advance payments made to unregistered suppliers for supply of goods or services or both
·       Advertisement expenses through banners
·       Advertisement expenses through posters
·       Advertisement in magazine
·       Advertisement in media
·       Annual Maintenance Charges (AMC)
·       Bank Charges
·       Broker Fees and Charges
·       Call Centre Expenses
·       Club and Membership Fees
·     Composition Scheme opted persons are not eligible for input tax credit and hence the tax payable if any on the reverse charge mechanism must be paid at normal rates separately in addition to the composition levy.
·       Consumables
·       Conveyance Expenses by all vehicles with A/c
·      Conveyance Expenses by Radio Taxi which operates through radio signals i.e. when a customer calls up the helpline number of the radio taxi, the operator communicates with driver via radio signals to locate the nearest taxi and the taxi reaches the customer at the specific place.
·       Conveyance Expenses by Train in A/c coach
·       Conveyance Expenses by Train in First Class
·       Customer schemes by MSIL
·       E-commerce Operators
·       Extended warranty cancellation charges
·       Food Expenses
·       Free Service Camp Expenses
·       Freight charges for goods at the goods GST Rates
·     Gifts by employer of value above Rs.50000.00 will be treated as outward supply and liable to GST
·       Gold ornaments sold by an unregistered supplier to a registered supplier
·     Goods Transport Services by Goods Transport Agency (GTA) to any factory, society, co-operative society, registered person, body, corporate, partnership firm, casual taxable person located in the taxable territory
·       House keeping charges
·       Legal Services by advocates by an individual advocate, including a senior advocate or a firm of advocates to any business entity located in the taxable territory
·       Non-resident Service provider
·       Once the expenses exceeds Rs.5000.00 per day, GST is payable on the entire expenses under Reverse Charge Mechanism.
·       Packing charges for goods at the goods GST Rates
·   Purchases of taxable goods / services above Rs.5000.00 per day from unregistered suppliers on the entire purchase and there is no exemption for the first Rs.5000.00
·       Refreshment Expenses
·    Registered dealers have to pay GST on Reverse charge mechanism on the purchases effected from the compounded scheme dealers.
·    Registered dealers have to pay GST on Reverse charge mechanism on the purchases effected from the unregistered dealers.
·  Rent paid for premises used for commercial purpose by the commercial user to unregistered person
·   Reverse Charge Mechanism will be applicable where the aggregate value of such supplies of goods or service or both received by a registered person from any or all the suppliers, who is or are not registered, exceeds five thousand rupees in a day.
·       Services of a Director to a company
·       Services provided by way of sponsorship to any body corporate or partnership firm by any person to any body corporate or partnership firm located in the taxable territory
·       Services supplied by a director of a company or a body corporate to the said company or the body corporate by a director of a company or a body corporate to the company or a body corporate located in the taxable territory
·     Services supplied by a recovery agent to a banking company or a financial institution or a non-banking financial company by a recovery agent to a banking company or a financial institution or a non banking financial company, located in the taxable territory
·     Services supplied by an arbitral tribunal to a business entity by an arbitral tribunal to any business entity located in the taxable territory
·      Services supplied by an insurance agent to any person carrying on insurance business by an Insurance Agent to any person carrying on insurance business, located in the taxable territory
·    Services supplied by the Central Government, State Government, Union Territory or local authority to a business entity excluding (1) renting of immovable property and (2) services specified (i) services by the Department of Posts by way of Speed post, express parcel post, life insurance and agency services provided to a person other than Central Government, Stat Government or Union territory or local authority (ii) services in relation to an aircraft or a vessel inside or outside the precincts of a port or an airport (iii) transport of goods passengers by Central Government, State Government, Union Territory or local authority to any business entity located in the taxable territory.
·       Supplies received from Un-registered persons
·       Supply of Bidi wrapper leaves (tendu) by Agriculturist to any registered person
·       Supply of Cashew nuts, not shelled or peeled by Agriculturist to any registered person
·       Supply of Goods or Services in relation to Exports and Deemed Exports (RCM will be applicable under IGST)
·       Supply of Goods or Services to a taxpayer located in non-taxable territory i.e. supplies made to Special Economic Zone Units or Special Economic Zone Developers (RCM will be applicable under IGST).
·    Supply of lottery by State Government, Union Territory or local authority to Lottery Distributor of Lottery selling Agent
·    Supply of services by an author, music composer, photographer, artist or the like by way of transfer or permitting the use or enjoyment of a copyright covered under section 13(1)(a) of the Copyright Act, 1957 relating to original literary, dramatic, musical or artistic works to a publisher, music company, producer or the like by an Author or music composer, photograph her, artist, or the like to publisher, music company, producer or the like, located in the taxable territory
·    Supply of Silk yarn by any person who manufactures silk yarn from raw silk or silk work cocoons for supply of silk yarn to any registered person
·       Supply of Tobacco leaves by Agriculturist to any registered person Supply
·  The aggregate value of such supplies of goods or service or both received by a registered person from any or all the suppliers, who is or are not registered, exceeds five thousand rupees in a day i.e. if the expenses in a day exceeds Rs.5000.00 the taxpayer has to pay GST under Reverse Charge Mechanism.
·       Training Expenses

HOW TO ACCOUNT FOR THE REVERSE CHARGE MECHANISM TRANSACTIONS

https://abhivirthi.blogspot.com/2017/10/reverse-charge-mechanism-under-gst-with.html

As per Section 32 (3) of the CGST Act, 2017 the registered person who is liable to pay tax under sub-section (3) and (4) of Section 9 shall issue an invoice in respect of goods or services or both received by him from the supplier who is not registered on the date of receipt of goods or services or both and a registered person who is liable to pay tax under sub-section (3) and (4) of Section 9 shall issue a payment voucher at the time of making payment to the supplier.

(In simple language purchases from unregistered persons have to be made through bought invoices and payment to be made through payment vouchers)

As per Notification No.8/2017 dated June 28, 2017, on the recommendations of the Council, exempted Intra-State supplies of goods or services or both received by a registered person from any supplier, who is not registered, from the whole of the central tax leviable thereon under sub-section (4) of Section 9 of the CGST Act, 2017.

Provided that the said exemption shall not be applicable where the aggregate value of such supplies of goods or services or both received by a registered person from any or all the suppliers, who is or are not registered, exceeds Rs.5000 in a day.

Time of Supply under rcm

The time of supply is the point when the supply is liable to GST.

One of the factors relevant for determining time of supply is the person who is liable to pay tax. In reverse charge, the recipient is liable to pay GST.

Thus, time of supply for supplies under reverse charge is different from the supplies which are under forward charge. In case of supply of goods, time of supply is earliest of: -

·       date of receipt of goods; or
·       date of payment as per books of account or
·       date of debit in bank account, whichever is earlier; or
·       the date immediately following thirty days from the date of issue of invoice or similar other document.

In case of supply of services, time of supply is earliest of: -
·       date of payment as per books of account or date of debit in bank account, whichever is earlier; or

·       the date immediately following sixty days from the date of issue of invoice or similar other document.

Provided that if any of the above clauses is not determinable, the time of supply shall be the date of entry in the books of accounts of the recipient of supply.

The recipient of the supply is required to issue a Tax Invoice for goods or services received from unregistered person as per Section 31(2) (f) of the Central Goods and Services Tax Act. 2017.

The recipient is required to issue a payment voucher at the time of making payment to the unregistered supplier according to Section 31(2) (g) of the Central Goods and Services Tax Act. 2017.

input tax credit adjustment

According to Section 2(62) of the CGST Act, 2017, input tax includes

·       the tax payable under the provisions of sub-section (3) and (4) of Section 9 of the CGST Act;
·       the tax payable under the provisions of sub-section (3) and (4) of Section 5 of the Integrated Goods and Services Tax Act;
·       the tax payable under the provisions of sub-section (3) and (4) of Section 9 of the State Goods and Services Tax Act; or
·       the tax payable under the provisions of sub-section (3) and sub-section (4) of Section 7 of the Union Territory Goods and Services Tax Act

A registered person will be able to take the credit of tax paid under reverse charge subject to condition that the payment for the supplies received by the recipient under reverse charge made within 60 days from the date of issue of RCM invoice.

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