QRMP Scheme under GST: – QRMP Scheme stands for Quarterly Return Monthly payment scheme. Under QRMP Scheme, registered persons will be required to file GSTR -1 and GSTR -3B on quarterly basis and require paying GST liability on monthly basis.
QRMP Scheme Eligibility:- A Registered person having aggregate turnover of upo Rs 5 Crore in the preceding financial year is eligible for QRMP Scheme under GST. However, if turnover cross Rs 5 crore limits during a quarter in a financial year then registered person shall not be eligible for QRMP Scheme under GST from the next quarter. In such cases where turnover limit crossed, registered persons have to ensure that the return filing option is changed to monthly from the next quarter. To avoid any default one has to verify turnover limit achieved every quarter and ensure that the turnover is within limit of Rs 5 Crore.
Aggregate annual Turnover for the previous year shall be checked from the common portal. Common portal calculated turnover on the basis of details furnished by tax payers in the preceding year GST returns.
Following type of Registered persons is not eligible for QRMP Scheme:-
1. Composition Taxpayer
2. Input Service Distributor
3. Non Resident Taxable person
4. Department or establishment of State or Central Govt
5. If one crosses turnover of Rs 5 cr. during the quarter.
Exercising option for QRMP Scheme:- A Register person can opt in QRMP Scheme from 1st day of second month of preceding quarter to the last day of the first month of the current quarter. For Example if a registered person intending to avail of the QRMP scheme for the quarter “July to September” then registered person can exercise his option during 1st of May (i.e. First day of second month of preceding quarter) to 31st of July. At the time of opt in QRMP Scheme, registered person must have furnished the last return.
Registered persons are not required to exercise the QRPM option for every quarter separately. Once QRPM option under GST exercised then registered person shall continue to furnish future returns on quarterly basis unless they revise the said option.
QRMP Scheme GSTIN wise or Pan wise:- For calculation of aggregate annual turnover for QRMP Scheme eligibility, the turnover of PAN Shall be considered. However, for opting for scheme, taxpayer can opt in as per GSTIN wise.
For example: – If XYZ Ltd, is having PAN based turnover of Rs. 3.67 Cr, then it can opt for the scheme. Now, if it’s having 3 GSTIN X, Y, Z, and then GSTIN X can opt for the scheme. It depends on registered person for opt in QRMP scheme as per GSTIN wise.
It is not compulsory that all GSTIN should opt for the scheme.
Law amendments:- Government has issued following notifications to implement QRMP scheme under GST.
Section 97 of Finance Act (no 2) 2019 – QRMP Scheme Introduced
Notification no 81/2020 dated 10th Nov 2020 – Section 97 of Finance Act 2019 notified
Notification no 82/2020 dated 10th Nov 2020 – Amends the rules to prescribe the forms, manners and procedures for QRMP Scheme.
Notification no 84/2020 dated 10th Nov 2020 – Notifies the class of registered persons under proviso to section 39 of CGST Act to whom the QRMP Scheme shall be application.
Notification no 85/2020 dated 10th Nov 2020 – Notifies special procedure for making Tax payment in First two months of a quarter.
Circular No 143/13/2020 dated 10th Nov 2020 – Provides clarification on QRMP Scheme.
Payment of GST under QRMP Scheme: – Under QRMP Scheme the registered person requires paying the tax due in each of the first two months of the quarter. The tax payment shall be done in FORM GST PMT – 06. The due date for tax payment shall be done on or before 25th day of next month. There are two options for tax payment under QRMP Scheme. (Notification 85/2020 dated 10th November 2020).
1. Fixed sum Method
2. Self Assessment Method
Fixed Sum method:- Registered person under QRPM scheme can pay fixed amount of tax in each of the first two months of the quarter. A prefilled challan in FORM GST PMT -06 is being made available on the portal. FORM GST PMT-06 (pre-filled) shall be an amount equal to 35% of the tax paid in cash in the last quarter where the return was furnished quarterly. In case where the return was furnished monthly then GSP PMT-06 challan shall be an equal to the tax paid in cash in the last month.
Let’s understand the Fixed sum method with the help of following examples:-
Example 1 – In case last return filed was on quarterly basis:-
| Tax paid in cash in last quarter | Tax required to be paid in each of months | ||
| CGST | 100 | CGST | 35 |
| SGST | 100 | SGST | 35 |
| IGST | 500 | IGST | 175 |
| Cess | 50 | Cess | 17.5 |
Example 2 – In case last return filed was on monthly basis:-
| Tax paid in cash in last month | Tax required to be paid in each of months | ||
| CGST | 50 | CGST | 50 |
| SGST | 50 | SGST | 50 |
| IGST | 90 | IGST | 90 |
| Cess | 50 | Cess | 50 |
Self Assessment method: – The registered persons can pay the tax due by considering the tax liability on output supplies and Input tax credit on Inward supplies. With the help of FORM GSTR 2B, registered persons can ascertain the Input tax credit. Under self assessment method tax payment shall be done in FORM GST PMT-06.
At the time of generating the tax challan, tax payers should select “Monthly payment for quarterly taxpayers” as reason for generating the tax challan. The tax deposited in first two months shall be debited from cash ledger at the time of filling of GSTR 3B for said quarter. Liability in respect of RCM transactions must be paid through the challan.
Refund of Tax Excess Deposit:- In case, if a registered persons has deposited the excess amount in first two months of a quarter then refund of excess amount to claimed only after the furnishing the Form GSTR 3B for that quarter. The amount deposited by registered persons in first two months of a quarter cannot be used for any other purpose other than Form GSTR 3B.
Form GSTR 3B under QRMP Scheme:- In QRMP Scheme, registered persons would be required to furnish Form GSTR 3B on quarterly basis. The due date for furnishing Form GSTR 3B would be on or before 22nd or 24th day of the month succeeding such quarter. In Form GSTR 3B, registered persons shall declare the output liability and Input tax credit and calculate the tax liability for the quarter. The tax amount deposited in first two months of a quarter shall be adjusted with liability calculated in Form GSTR 3B. After the adjustment, any amount left then such amount may either be claimed as refund or may be used for any other purpose in subsequent quarter.
If a registered person cancelled GST registration in first two months of a quarter then he is still required to furnish return in Form GSTR 3B for the relevant tax period.
Interest on Non payment of Tax:-
Interest payment in case of Fixed sum method:- No interest would be payable in case tax liability of First two months for a quarter paid using fixed sum method within due date, However, Registered person has to ensure that entire tax liability shall be discharge for the quarter in Form GSTR 3B within due date.
For Example:- If Rs 100 paid as cash in previous quarter before QRMP Scheme. As per Fixed sum method Rs 35 paid by 25th May and Rs 35 paid by 25th June and actual liability for April and May was Rs 40 and Rs 42. In this case no interest payable on shortfall of Rs 5 and Rs 7 of first two months of a quarter provided GSTR 3B filed by due date.
If payment is not done within due date then interest would be payable at the applicable rate (18%) from the due date of payment till the date of making such payment.
If GSTR 3B not filed within due date then interest would be payable on net cash liability for the quarter as reduced by payment done in First two month of a quarter for the period of delay.
For Example:- If Rs 100 paid as cash in previous quarter before QRMP Scheme. As per Fixed sum method Rs 35 paid by 25th May and Rs 35 paid by 25th June. In return for the quarter, it is found that total net cash liability is Rs 125. If registered person files the return after due date then interest would be payable at applicable rate on Rs 55 (Rs 125 – Rs 35 – Rs 25). Interest would be payable for the period between due date of Form GSTR 3B till the date of furnishing the Form GSTR 3B.
Also See, “Offences with Fine and Penalty under GST“
Interest payment in case of Self assessment method:- Under Self assessment method interest would be payable on any short payment of first two months of a quarter, Interest would be paid at the rate of 18% on such short payment from the due date of PMT -06 till the date of filling of GSTR 3B.
Please note that there is no late fee is applicable for delay in payment of tax in first two months of the quarter.
For any query you can write at taxhouseindia@gmail.com. Before making any decisions do consult with your professional or tax advisor.
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