What is the Quarterly Return Monthly Payment Scheme?
The GST COUNCIL in their 42nd Meet on 5th October 2020 proposed a quarterly return filing system for small taxpayers to be implemented w.e.f. 1st January 2021. QRMP or Quarterly Return Monthly Payment Scheme is an optional scheme that CBIC has rolled out for small scale businesses having aggregate turnover up to 5 crore rupees to furnish return on a quarterly basis along with monthly payment of tax. Thus, the small taxpayers would only need to file 8 returns (4 GSTR 1 and 4 GSTR 3B) in a year as compared to 16 returns a year at present.
This scheme would bring in a big relief to those taxpayers who may have been losing their eligible credits due to compliance of Rule 36(4) where their suppliers are filing GSTR 1 quarterly. Now, 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 duly reflected in the GSTR-2A and GSTR-2B of the customer based on which the customer can avail the input tax credit timely.
- The aggregate turnover (PAN wise) of the preceding FY will be considered for calculating the threshold limit of Rs. 5 cr.
- The option can be availed GSTIN wise. Therefore, few GSTINs for that PAN can opt for the Scheme and the remaining GSTINs can remain out of the Scheme.
- In case the aggregate turnover exceeds Rs. 5 cr during any quarter in the current financial year, the registered person shall not be eligible for the Scheme from the next quarter.
Time limit to opt for QRMP Scheme
- The facility is available online and can be availed throughout the year, in any quarter
- Option for QRMP, once exercised, will continue till registered person (RP) revises the option or his annual aggregated turnover exceeds INR 5 Cr.
Note: The RPs opting for the scheme can avail the facility of Invoice Furnishing Facility (IFF) so that the outward supplies to a registered person are reflected in their respective Form GSTR 2A & 2B.
Default Migration for the first quarter of the Scheme
In order to facilitate the taxpayers, it has been decided that for the first quarter i.e., January 2021 to March 2021, the registered persons having turnover up to Rs 5 cr and who have furnished the return in FORM GSTR-3B for October 2020 by 30th November 2020, shall be migrated on the common portal.
When to Opt-Out and How to Opt-out from the Scheme?
- Any taxpayer whose aggregate turnover has exceeded Rs. 5 cr in the FY 2020-21, shall opt out of the Scheme. The registered person shall not be eligible for the scheme from the next quarter.
- Similarly, the facility for opting out of the Scheme for a quarter will be available from the first day of the second month of the preceding quarter to the last day of the first month of the quarter.
- All persons who have obtained registration during any quarter or the registered persons opting out from paying tax under Section 10 of the CGST Act during any quarter shall be able to opt for the Scheme for the quarter for which the opting facility is available on the date of exercising option.
Invoice Furnishing Facility (IFF)
- The registered persons opting for the Scheme would be required to furnish the details of an outward supply in FORM GSTR-1 quarterly as per the rule 59 of the CGST Rule.
- For each of the first and second month of a quarter, such a registered person will have the IFF to furnish the details of such outward supplies to a registered person, as he may consider necessary, between the 1st day of the succeeding month till the 13th day of the succeeding month.
- The said details of outward supplies shall, however, not exceed the Rs. 50 Lakhs in each month. It may be noted that after 13th of the month, this facility for furnishing IFF for a previous month would not be available
- As a facilitation measure, a feature of continuous upload of invoices would also be provided for the registered persons wherein they can save the invoices in IFF from the 1st day of the month till 13th day of the succeeding month.
- 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.
- The said facility is not mandatory and is only an optional facility made available to the registered persons under the QRMP Scheme.
- The details of invoices furnished using the said facility in the first two months are not required to be furnished again in FORM GSTR-1. Accordingly, the details of outward supplies made by such a registered person during a quarter shall consist of details of invoices furnished using IFF for each of the first two months and the details of invoices furnished in FORM GSTR-1 for the quarter. At their 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.
Monthly payment of tax
- RPs (Registered Persons) need to pay the tax due in each of the first two months by 25th of the following month of the Quarter by depositing the due amount in FORM GST PMT-06, by selecting “Monthly payment for the quarterly taxpayer” as a reason for generating Challan
- RPs can either use the Fixed Sum Method (pre-filled challan) or the Self-Assessment Method (actual tax due), for a monthly payment of tax for the first two months, after adjusting ITC.
- RP’s are free to avail any of the above methods for payment in any of the two months of the quarter.
- No deposit is required for the month if the balance in the electronic cash ledger and/or electronic credit ledger is adequate for the tax due for the 1st month or 1st and 2nd month both or where there is nil tax liability.
- Tax deposited for the first 2 months can only be used for adjusting liability for the respective quarter in Form GSTR-3B and can’t be used for any other purpose till the filing of return for the quarter. A refund for the balance accumulated can only be claimed after filing of GSTR 3B of the respective quarter.
Quarterly GSTR 3B Return
- Such registered persons would be required to furnish FORM GSTR-3B, for each quarter, on or before 22nd or 24th day of the month succeeding such quarter.
- In FORM GSTR-3B, they shall declare the supplies made during the quarter, ITC availed during the quarter and all other details required to be furnished therein.
- 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.
- However, any amount left after the filing of that quarter’s FORM GSTR-3B may either be claimed as refund or may be used for any other purpose in subsequent quarters.
- In case of cancellation of registration of such person during any of the first two months of the quarter, he is still required to furnish a return in FORM GSTR-3B for the relevant tax period.
Under Self-Assessment Method
- The taxpayer needs to pay interest @ 18% on the net tax liability which remains unpaid or is paid beyond the due date for each of the first two months of the quarter i.e., in case PMT-06 if filed after 25th of the following month.
- Further, it is important to note that the taxpayer needs to pay interest @18% if there is any late payment of tax in the third month of a quarter. This stays applicable irrespective of Fixed Sum Method or Self-Assessment Method.
Applicability of Late Fee
- The late fee will be applicable on the delay in furnishing the quarterly GSTR-3B and GSTR 1 within due date, i.e., Rs. 50 per day (CGST : SGST) subject to a maximum late fees of Rs 5,000.
- However, it is clarified that no late fee is applicable for delay in payment of tax in the first two months of the quarter in form GST PMT-06.