New GST Scheme – Quarterly Returns Monthly Payment (QRMP)

Introduction:

As a part of the ‘Ease of Doing Business’ Initiative, the CBIC has come with a new Scheme for filing GST Returns named Quarterly Return Monthly Payment Scheme under Circular No. 143/13/2020-GST on 10^th November 2020. This helps the small taxpayers whose yearly turnover is less than INR 5 Crore. This scheme allows the Taxpayers to File returns Quarterly and tax payment Monthly effectively from January 2021.

Who are Eligible and who can opt-out from the QRMP Scheme:

Eligibility:

A taxpayer (taxpayer/persons) who is registered on the GST Portal and is filing the return in Form GSTR-3B and has an aggregate yearly turnover of up to 5 Crore INR of the preceding financial year are eligible for this new scheme of QRMP. Some classes of Taxpayers are by default in the criteria of this scheme are automatically redirected in this scheme. This bifurcation of the classes of the taxpayer is mentioned below:

Sr. No.	Registered Taxpayers (Taxpayers) having aggregate turnover	Default Migrated Option
1	Registered Taxpayer whose yearly turnover is upto 1.5 Crore and are filing FORM GSTR-1 every month in current FY	Monthly Return
2	Registered Taxpayer whose yearly turnover is up to 1.5 Crore and are filing FORM GSTR-1 every quarter in current FY	Quarterly Return
3	Registered Taxpayer whose yearly turnover is more than 1.5 Crore but does not exceeds 5 Crore.	Quarterly Return

The taxpayers are suggested to file the return for October 2020 in November 2020 in time so that they could be eligible for the new Scheme of QRMP. The Taxpayers who have not filed the return for October 2020 till 30^th November 2020 will not be able to Migrate to this QRMP Scheme. The Taxpayers in Sr. No. 1 can change their default option and opt for quarterly filing of GSTR-3B between 5^th December 2020 and 31^st January 2021.

Timeline for exercising option under QRMP Scheme during FY 2020-21
Sr. No.	Period – Quarter	Timeline
1	April – June	1st Feb 2021 to 30th April 2021
2	July – Sept	1st May 2021 to 31st July 2021
3	Oct – Dec	1st August 2021 to 31st Oct 2021
4	Jan – March	1st Nov 2021 to 31st Jan 2022

When can a taxpayer Opt-Out:

In case the taxpayer exceeds the aggregate turnover of 5 Crore INR during any quarter of the current FY, then they need to opt-out from the scheme and they need to file the return every month, on the common portal from the succeeding quarter. If the aggregate turnover again falls below 5 Crore then they can again opt for this scheme.

If you want to migrate to QRMP Scheme or need to opt-out from the scheme manually then you have the right to do it anytime. You can opt-out from the GST portal anytime you wish by performing the following steps:

1. Visit GST Portal

2. Services

3. Returns

4. Opt-in for Quarterly Return option to opt-in or opt-out of the QRMP scheme.

Submitting details of Outward supplies:

The Registered Taxpayers who are sufficing the QRMP Scheme can use the facility of Invoice Furnishing Facility (IFF) but their aggregate turnover must be up to 1.5 Cr. The eligible Taxpayer who is filing GSTR-1 Quarterly needs to upload their Invoices every month from the 1^st to 13^th date of the succeeding month. The details submitted in IFF will be reflected in the GSTR 2A, 2B, 4A, or 6A of the recipients as applicable. The amount of the invoices is restricted up to 50 Lakhs per month. While opting the IFF is not mandatory and is only an optional facility made of the taxpayers registered under the QRMP Scheme.

Monthly Tax Payments for QRMP Scheme:

The Registered Taxpayer under the QRMP Scheme would require to pay the due tax monthly in each of the first two months of the quarter. The GST department has given the option to select any options from the two given options in QRMP Scheme. The two methods are;

1. Fixed Sum Method (FSM):

The taxpayer who is filing a Quarterly return in a preceding quarter has to pay 35% of the tax in the 1^st and the 2^nd month of the quarter. The balancing amount of tax is to be paid in the 3^rd month.

Sr. No.	Type of Taxpayer	Tax to be paid
1.	Who furnished GSTR-3B quarterly for the last quarter	35% of tax paid in cash (Electronic Cash Ledger) in the preceding quarter
2.	Who furnished GSTR-3B monthly during the last quarter	100% of tax paid in cash in the last month of the immediately preceding quarter

2. Self-Assessment Method (SAM):

Here the taxpayer can pay the tax liability by considering the tax liabilities on inward and outward supplies and as per the ITC available. The taxpayer has to manually pay the tax liability for the month and has to pay the same in form GST PMT-06. The approximate payable tax for every month can be viewed with the help of Form GSTR-2B.

There are certain conditions where no tax needs to be paid:

• 1^st Month of Quarter: The tax liability is Nil. OR The balance in the electronic cash ledger is adequate for the tax liability for the same month.
• 2^nd Month of Quarter: The tax liability is Nil. OR The balance in the electronic cash ledger is adequate for the cumulative tax liability for the first two months of the quarter.

While paying the tax, you will need to select the Payment Method for which you are paying the Tax.

Due Dates for the Quarterly filing GSTR-3B:

Sr. No.	Group	GST Registration in States and Union Territories	Due Date
1	Group-A	Chhattisgarh, Madhya Pradesh, Gujarat, Dadra and Nagar Haveli, Daman and Diu, Maharashtra, Karnataka, Goa, Lakshadweep, Kerala, Tamil Nadu, Puducherry, Andaman and Nicobar Islands, Telangana and Andhra Pradesh	22nd of the month succeeding such quarter
2	Group-B	Jammu and Kashmir, Ladakh, Himachal Pradesh, Punjab, Chandigarh, Uttarakhand, Haryana, Delhi, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Mizoram, Manipur, Tripura, Meghalaya, Assam, West Bengal, Jharkhand and Odisha	24th of the month succeeding such quarter

Interest Under QRMP Scheme:

Sr. No.	Scenario	Interest to be paid
1	Tax liability mentioned in pre-filled form GST PMT-06 is not paid by 25th of the following month	18% of the tax liability (from 26th of the following month till the date of payment)
2	The final tax liability for the first two months is higher than the tax amount paid through pre-filled form GST PMT-06, and such excess liability has not been paid within the quarterly GSTR-3B due date	18% of the tax liability (from GSTR-3B due date* till the date of payment)

The interest will be applicable as follows if the taxpayer opts for the Self-Assessment Method (SAM):

The taxpayer has to pay interest @ 18% on the net tax liability which remains unpaid or paid beyond the due date for the first two months of the quarter.

Late Fee under QRMP Scheme:

Name of the Act	Late fee for every day of delay	Late fee for every day of delay (in case of ‘Nil’ tax liability)
CGST Act	Rs.25	Rs.10
SGST Act	Rs.25	Rs.10
IGST Act	Rs.50	Rs.20

Conclusion:

The QRMP Scheme is the best move that will provide some great benefits for the small taxpayers. This will be a great move for both the Small Tax Payers as well as the Big Tax Payers who are losing a lot of credits due to non-reflection of invoice entries in GSTR-2A. The reason for this is many suppliers are filling GSTR-1 quarterly. Hence, this will eventually lead to saving both time and money. Also, as per the Government Perspective, this scheme is expected to reconnect the revenue leakages and frauds as it would be surely decreasing the fake invoicing and fake input tax credit. Hence it can be said that after the successful implementation of this scheme it would be a win-win situation for all.

FAQ:

Q-1 When can I avail the QRMP Scheme?

Ans: The facility to avail the Scheme on the common platform is available throughout the year. If a person wants to avail of the scheme for “April to June” they can join during any time from 1^st March to 30^th April. The registered taxpayers do not need to do this exercise every year.

Q-2 Can I still file the Nil return through SMS?

Ans: Yes, you can still file your Nil return through SMS.

Q-3 How to make Monthly Payment of Tax and what is the due date of payment?

Ans: The registered person under the QRMP Scheme would be required to pay the tax due in each of the first two months of the quarter by depositing the due amount in Form GST PMT-06 and the amount of tax shall be deposited by the 25th day of next month.

Q-4 Who is not eligible for QRMP Scheme?

Ans: Following taxpayers are not eligible for the QRMP Scheme-

• Composition dealer
• ISD (Input Service Distributor)
• NRTP (Non-resident Tax Payer)
• OIDAR Service provider (Online Information and Database Access and Retrieval)
• TDS Deductor
• TCS Deductor

Q-5 How the recipient of a quarterly filer will get their Input Tax Credit?

Ans: The buyer of a quarterly filer can take the ITC based on auto reflection in GSTR 2A & 2B. The quarterly filer can upload data of invoices on monthly basis. A special facility is provided for it. It is called the IFF facility. The taxpayer can upload a B2B invoice up to Rs. 50 lac each month using this facility. Thus, the ITC of quarterly files is also available to the recipient.