In order to further ease the process of doing business, the GST Council in its 42nd meeting held on 05.12.2020 has introduced the QRMP Scheme i.e. Quarterly Returns Monthly Payment Scheme w.e.f 01.01.2021 for all the registered taxpayers having aggregate turnover upto INR 5 crores in the preceding financial year.
Taxpayers having aggregate turnover upto INR 5crores in the preceding financial year can take the opportunity to avail this scheme to further ease the compliance burden.
Circular No. 143/13/2020-GST dated 10.11.2020 was issued to explain the QRMP Scheme in simple terms. An attempt has been made to explain the circular in relevant context.
Features of the QRMP Scheme –
A. Eligibility for the Scheme –
1. Vide Notification No. 84/2020- Central Tax dated 10.11.2020, a registered person who has an aggregate turnover of upto 5 crore rupees in the preceding financial year is eligible for the QRMP Scheme;
2. This new scheme will be effective from 01.01.2021;
3. Further, in case aggregate turnover exceeds INR 5 crore rupees during any quarter in the current financial year, the registered person shall not be eligible for the scheme from the next quarter.
B. Exercising option for QRMP Scheme –
1. It is not required to exercise the option every quarter. Where such option has been exercised once, the registered person shall continue to furnish the return as per the selected option for future tax periods, unless they revise the said option;
2. For the first quarter of the scheme i.e. for the quarter January, 2021 to March, 2021, all the registered persons, whose aggregate turnover for the FY 2019-20 is upto 5 crore rupees and who have furnished the return in Form GSTR-3B for the month of October, 2020 by 30th November 2020 shall be migrated as below –
|S.N.||Class of registered person||Default Option|
|1.||Registered persons having aggregate turnover of up to 1.5 crore rupees who have furnished FORM GSTR-1 on quarterly basis in the current financial year||Quarterly return|
|2.||Registered persons having aggregate turnover of up to 1.5 crore rupees who have furnished FORM GSTR-1 on monthly basis in the current financial year||Monthly return|
|3.||Registered persons having aggregate turnover more than 1.5 crore rupees and up to 5 crore rupees in the preceding financial year||Quarterly return|
3. Registered persons can change the above default option, if required, from 05.12.2020 to 31.01.2021.
C. Furnishing of details of outward supplies –
1. Form GSTR-1 shall be filed quarterly under the QRMP Scheme;
2. For first and second months of the quarter, such a registered person shall have a “Invoice Furnishing Facility – (‘IFF’)”, wherein details of outward supplies can be furnished from 1st day of the succeeding month till the 13th day of the succeeding month;
3. The details of outward supplies shall not exceed the value of INR 50 lakhs in each month;
4. After 13th of the month, this facility of furnishing IFF for previous month would not be available;
5. The facility of furnishing details of invoices in IFF has been provided so as to allow details of such supplies to be duly reflected in the Form GSTR-2A and Form GSTR-2B of the concerned recipient;
6. At his option, a registered person may choose to furnish the details of outward supplies made during a quarter in FORM GSTR-1 only, without using the IFF.
D. Monthly Payment of Tax –
1. Under QRMP Scheme, tax due in each of the first two months of the quarter is required to be paid by 20th of the succeeding month in Form GST PMT-06;
2. While generating the challan, taxpayers should select “Monthly payment for quarterly taxpayers” as reason for generating the challan;
3. Following 2 options are provided below for monthly payment of tax during the first two months –
I. Fixed Sum Method :
1. A pre-filled challan in FORM GST PMT-06 is made available on the portal for an amount equal to 35% of the tax paid in cash in preceding quarter where the return was furnished quarterly; OR equal to the tax paid in cash in the last month of immediately previous quarter where the return was furnished monthly;
2. For easy understanding, an illustration is tabulated below –
a. In case the last return filed was on quarterly basis for Quarter Ending March, 2021:
|Tax paid in Cash in Quarter (January – March, 2021)||Tax required to be paid in each of the months – April and May, 2021|
b.In case the last return filed was monthly for tax period March, 2021:
|Tax paid in Cash in March, 2021||Tax required to be paid in each of the months – April and May, 2021|
II. Self-Assessment Method:
1. Under QRMP Scheme, taxpayers can also discharge the tax due in FORM GST PMT-06 on a self-assessment basis by considering the tax liability on inward and outward supplies and input tax credit (‘ITC’) available;
2. In order to ascertain the ITC available for a month, an auto drafted ITC statement has been made available on the portal in FORM GSTR-2B.
E. Quarterly filing of GSTR-3B –
1. Under this scheme, FORM GSTR-3B for each quarter is required to be filed on or before 22nd or 24th day of the month succeeding such quarter;
2. The amount deposited by the registered person in the first two months shall be debited solely for the purposes of offsetting the liability furnished in that quarter’s FORM GSTR-3B;
3. In case of cancellation of registration of such person during any of the first two months of quarter, he is still required to furnish return in FORM GSTR-3B for the relevant tax period.
F. Applicability of Interest –
I. For registered person making payment of tax by opting Fixed Sum Method
1. No Interest would be payable in case the tax due is paid in the first two months of the quarter by way of depositing auto-calculated fixed sum amount by the due date as detailed above in Para D(I);
2. In case such payment of auto-calculated fixed sum amount in FORM GST PMT-06 is not done by the due date, interest would be payable at the applicable rate (18%), from the due date of furnishing FORM GST PMT-06 till the date of making such payment;
3. Further, if Form GSTR-3B for the quarter is furnished beyond due date, interest would be payable as per section 50 of the CGST Act on net tax liability.
II. For registered person making payment of tax by opting Self-Assessment Method
Interest amount would be payable as per section 50 of the CGST Act on net tax liability which remains unpaid/paid beyond the due date for the first two months of the quarter.
Before the introduction of this scheme, many taxpayers eligible for quarterly filing of GSTR-1 could have opted for monthly filing of GSTR-1 just to ensure that the invoices are being uploaded on a monthly basis and the same can be reflected in GSTR-2A of the customer based on which customer is eligible for input tax credit.
However, with the introduction of QRMP scheme, Invoice Furnishing Facility (‘IFF’) will help the taxpayers to opt for quarterly filing of returns (GSTR-1 as well as GSTR-3B) and simultaneously upload the invoices on a monthly basis which will be reflected in the GSTR-2A and GSTR-2B of the customer based on which customer will avail the input tax credit. There is two fold benefit with the introduction of this scheme –
i. Vendors eligible for quarterly filing of returns will not be asked to opt for monthly filing of returns (which was done for invoices to get reflected in GSTR-2A on monthly basis);
ii. With the help of IFF, invoices will now be reflected in GSTR-2A and GSTR-2B of the customer with quarterly filing of GSTR-1 and GSTR-3B.