Indian taxation system at present is very complicated and involves multiple taxes on the same commodity which results in inflated prices. Attempts at simplifying the taxation system have been made time and again and the proposed goods and services tax (hereinafter “GST”) model is one such attempt at simplifying and unifying the tax structure in the country. The Kelkar Task Force Report which first conceived the idea of a unified value added tax for the whole country in the shape of goods and services tax was received with much enthusiasm because of its claim at simplifying the tax system and curing it of its ills, such as, tax cascading effect and making the taxation structure suited to the federal structure of the country.
The Constitution (One Hundred Fifteenth Amendment) Bill, 2011 was the first bill relating to implementation of GST which was introduced in Parliament on 11-3-2011. The Standing Committee on Finance was also constituted to study the Bill which submitted its report in August 2013. However, the pending Bill lapsed with the dissolution of the 15th Lok Sabha. Thereafter the Constitution (One Hundred Twenty-Second Amendment) Bill, 2014 (hereinafter “the Bill”) was introduced in the Lok Sabha on 19-12-2014 for implementation of GST and for conferring concurrent powers on the Centre and the States to facilitate such implementation. The Bill has been passed by the Lok Sabha and ultimate introduction of the GST model would depend on its passage through the Rajya Sabha and subsequent ratification by one-half of the States in accordance with the procedure provided by Article 368 of the Constitution.
Prime Minister Narendra Modi’s Government aims at rolling out the GST by April 2016 and for that purpose has set up a GST cell to act as a Secretariat to the Empowered Committee of State Finance Ministers who have been allotted the task of looking into the Bill and ensuring its smooth passage through Parliament and thereafter, monitoring its progress through the State Legislatures. Work to set up an IT infrastructure to support the computerised tax collection which GST envisages is also in progress.
However, the Government has till date failed to reach a wide consensus with all the stakeholders with respect to the requirement of GST in India leave alone the finer details of the model. While debate continues about the need for GST and the model which is best suited to the unique conditions in India, the Government needs to engage with and respond to the criticisms which are emerging from different quarters. Only after it has put to rest the apprehensions of the States regarding encroachment upon their autonomy and loss of revenue and has taken care of the anticipation of increased tax burden on consumers and small traders, can it proceed with the programme which it hails as the ultimate milestone in the process of indirect tax reforms in India.
This article looks at the need for GST in India and the benefits which the Government and the policy-makers believe would accrue from the successful implementation of GST. The Bill pending in Parliament as well as the report of the Empowered Committee has been analysed to infer the salient features of the GST scheme and the exact manner in which it will be implemented. Finally, the concerns arising from different quarters especially those which have been raised by the States have been dealt with in an attempt to analyse whether the prospective benefits accruing out of the introduction of the GST outweigh the apprehended drawbacks. An attempt has been made to provide clarity about the proposed GST model and look at the federal implications of such an initiative.
Objectives behind introduction of GST in India and its prospective benefits
GST is recognised internationally as a destination based consumption tax. The Constitution (One Hundred Twenty-Second Amendment) Bill, 2014 defines the goods and services tax as “any tax on supply of goods, or services or both except taxes on the supply of the alcoholic liquor for human consumption”.
The first mention of the GST System in Indian policy making was in the Central Budget of 2007-2008 when the then Finance Minister envisioned introduction of the system in the country by 1-4-2010 and instructed the Empowered Committee of State Finance Ministers to lay down a road map for the same. This Committee in its first discussion paper on GST saw the GST Scheme as the next logical step in the indirect tax reforms which had been initiated by the substitution of the central excise duty at the national level and the services tax at the State level by the central valued added tax (hereinafter Cenvat). Cenvat was introduced in India to address the issues of multiple taxation and “tax on tax” as under the traditional regime at the first level the input was taxed and at the output level the output was taxed along with the input tax load. VAT introduced a set-off system where deduction was made from the overall tax burden for the input tax. This step in indirect tax reforms received positive responses from the industries and benefitted trade and resulted in tax revenue growth.
Despite the success of VAT, there were certain shortcomings which GST aims to improvise upon. Certain central taxes, such as, additional customs duty, surcharges, etc. have not been included in the Cenvat and the value added chain in the distribution trade below the manufacturing level has not been captured by the VAT system. Indirect taxes such as, luxury tax and entertainment tax have not been included in the State level VAT. The State VAT is taxed on the value of goods including the Cenvat and this further contributes to the cascading effect as the tax is being charged not on the actual value of the goods but the value of the goods which includes the Central VAT. The Empowered Committee while analysing the existing VAT system was of the view that there should be integration of the VAT on goods and services as the final product is produced on the basis of the harmonious integration of physical inputs as well as services in appropriate amounts.
The system of GST uses set-off mechanism from the original producer’s point to the retailer’s level to remove cascading effect of both the taxes on goods and services and thus, takes care of the value addition in that part of the chain below the manufacturing level which had been ignored by VAT. Cenvat is confined to the “manufacturing” stage and does not extend to the distribution chain beyond that. The following table explains the set-off mechanism used by GST as well as the manner in which “tax on tax” is avoided by it.
|Stage of supply chain
||Purchase value of Input
||Value at which supply of goods and services made to next stage
||Rate of GST
||GST on output
||Input Tax credit
||Net GST=GST on output – Input tax credit
||13-10 = 3
||15-13 = 2
||16-15 = 1
Fig 1: Working of GST at the different levels of manufacture and distribution of goods.
The argument of covering that part of the chain which had been missed by VAT and prevention of cascading effect was used to justify the need for introduction of a new system and not just changing the existing system of VAT by adding service tax to it. Moreover, GST would remove the burden of central sales tax (hereinafter “CST”) and the overall tax burden on goods would fall. Although CST has been lowered from 4% to 2% yet the burden has not been fully phased out. CST is an origin based tax which is charged by the Centre and collected by the States and it cannot be set-off against VAT in many situations. As far as revenue of States and the Centre is concerned, the widening of tax base and possible improvement in tax compliance may result in revenue gains. The inclusion of almost all indirect taxes into the GST would result in decreased compliance costs.
Out of all the objectives behind introduction of the GST system and the benefits which would arise from such a system, the one which concerns the consumer the most is the actual impact of the tax on the cost of final products. It has been speculated that introduction of GST would result in lowering of the price of the final product. This is because the present systems of Cenvat and State VAT have been unsuccessful in completely removing the cascading effect of taxes which results in increased prices. Also, at present there are many Central and State taxes at the stages of production and distribution where no set-off mechanism in the form of input tax credit is available. GST by removing the cascading effects of all taxes and providing an input tax credit mechanism and subsuming all the major Central and State taxes would ensure that the prices of goods are controlled and under the proposed system the prices of final products would be lower than what they are at present.
A complete transparent chain of set-offs and better tax compliance resulting in lower tax burden on manufacturers would bring relief to industry, trade and agriculture. The decrease in the price of goods manufactured in India under GST would make Indian goods more competitive in foreign markets and improve export business.
The proposed GST system has two components, the Central and the State GST which is a reflection of the federal structure of the Indian State. The Empowered Committee while dealing with the question of dual GST gave constitutional requirement of fiscal federalism as the only reason for introduction of a separate State GST. The Constitution has given both the Centre and the States the power to levy taxes. The power to levy taxes which have not been mentioned in either of the three lists rests with Parliament. Thus, the taxation powers of the Centre and the State have been very well demarcated in the Constitution and dual GST is an attempt to maintain this demarcation and to ensure that the taxation powers of the States are not encroached upon by the Centre.
The present GST system provides for PAN based registration of all dealers and makes provision for filing of returns on a common portal and a more efficient information sharing mechanism between Centre and the States. These provisions would greatly help in prevention of tax evasion and boost revenue from taxes by ensuring efficient tax administration and tax compliance. Under the existing system, reliefs had been granted in tax payment to create an environment conducive for investment but it is expected that under the GST model such exemptions would be controlled if not completely eliminated.
GST also promises greater transparency because of the inbuilt tax credit system in the model. It proposes to make the intra and inter-State rates of taxes the same and eliminate the problem of rate arbitrage. This might prove to be an incentive for tax compliance. The tax rates and grounds for tax exemptions in States are quite arbitrary and large variations are observed between tax schemes of different States. The flexibility offered to the States allows them to compete with each other to attract investments. They do so by reducing tax rates arbitrarily which ultimately leads to tax wars between the States. The States which face the brunt of such tax wars at present have no recourse but the GST model proposes to set up a GST Council which will recommend tax rates to the Centre and States. The GST Scheme envisions the establishment of the GST Dispute Settlement Authority which would act as the appropriate forum for handling complaints of deviant action of States that results in loss of revenue for another State.
The Standing Committee of Finance which analysed the Constitution (One Hundred Fifteenth Amendment) Bill, 2011 recognised the ability of the GST Scheme to expand the extent to which economic activities could be covered by taxes and consequentially increase the tax base. It was optimistic that introduction of the tax system in India would improve the competitiveness of the indigenous industries and contribute to the development of a common national market for goods and services.
The GST scheme envisages high goals and projects great benefits to justify its introduction. However, actual delivery upon the promises which have been made would encounter several practical difficulties. The study of prospective obstacles in the implementation of GST as well as an analysis of its shortcomings requires us to understand the salient features of the GST model.
Salient features of the Constitution (One Hundred and Twenty-Second Amendment) Bill, 2014
The Indian Constitution provides for fiscal federalism in the form of elaborate division of taxation powers between Centre and States with specific entries being present in the Union and State List to this effect. It can be said that sales tax is the only mass-based tax assigned to the States and constitutes the backbone of their fiscal autonomy. Collection of sales tax is done by the States because it involves dealing with dealers spread across the length and breadth of the State. The Centre has limited powers to tax commodities extending only to duties of excise. It has thus, been argued that it was never the intention of the Constitution-makers to give extensive powers to the Centre to levy domestic trade taxes and allowing the same now through the proposed GST model substantially effects the federal nature of the Constitution.
The Bill introduces a new article in the Constitution, Article 246-A which provides concurrent powers to Centre and the States for making laws relating to goods and services tax. The proposed Article 246-A reads as follows:
“246-A. Special provision with respect to goods and services tax.—(1) Notwithstanding anything contained in Articles 246 and 254, Parliament, and, subject to clause (2), the legislature of every State, have power to make laws with respect to goods and services tax imposed by the Union or by such State.
(2) Parliament has exclusive power to make laws with respect to goods and services tax where the supply of goods, or of services, or both takes place in the course of inter-State trade or commerce.
Explanation.—The provisions of this article, shall, in respect of goods and services tax referred to in clause (5), of Article 279-A, take effect from the date recommended by the Goods and Services Tax Council.”
The residuary powers of Parliament are also sought to be amended by the Bill by making the provisions of Article 248 subject to the provisions of Article 246-A. The Bill also makes provision for introduction of Article 269?A which deals with apportionment of GST collected by the Centre on inter-State trade or commerce. The article provides for apportionment between the Union and the States to be done in a manner provided by Parliament by law based on the recommendations of the Goods and Services Tax Council. The revenue from the proposed GST shall be divided between the Centre and the States like all the other duties and taxes mentioned in the Union List, that is, based on the recommendations of the Finance Commission or as prescribed by the President by order.
The Bill also proposes to establish a Goods and Services Tax Council which would consist of the Union Finance Minister as the Chairperson, the Union Minister of State in charge of Revenue or Finance and the Minister in charge of Finance or Taxation or any other Minister nominated by each State Government as members. The functions of the Council laid down in the Bill include recommendations to the Union and the States on the taxes levied by the Union, States and local bodies which may be subsumed in the GST. The Council may also make recommendations about tax exemptions, model GST tax laws, principles of levy, apportionment of integrated goods and services tax (hereinafter “IGST”), threshold limit of turnover for tax exemptions, the rates including floor rates, special rates for specified periods, special provisions for the States of Arunachal Pradesh, Assam, Jammu and Kashmir, Manipur, Meghalaya, Mizoram, Nagaland, Sikkim, Tripura, Himachal Pradesh and Uttarakhand. The Council has also been given the power to make recommendations on any other matter related to GST as it may decide from time to time. The Bill directs the Council to be guided in its actions by the need for a harmonised structure of GST and the development of a harmonised market for goods and services. The Council may provide for a dispute resolution mechanism to deal with the disputes arising out of its recommendations.
The proposed GST Scheme also includes an additional tax on supply of goods, not exceeding one per cent in the course of inter-State trade and commerce to be levied by the Centre for a period of two years or such other period as the GST Council may recommend. The proceeds out of this additional tax except where the proceeds accrue from Union Territories shall be assigned to the States from where the supply originates and Parliament may make laws for determining the place of origin from where supply of goods take place in the course of inter-State trade or commerce.
The Council may also make recommendations to Parliament to frame laws to pay compensation to the States for loss of revenue arising on account of implementation of GST for the period specified in the law, provided such period may not exceed five years. The Bill aims at removing any difficulties which may arise in giving effect to the GST Scheme as outlined in the Bill or difficulties arising out of the transition from the previous taxation system to the new one. It empowers the President to pass an order making such provisions or modifications to existing provisions, as may appear necessary to him for the purpose of implementation of GST. Such an order must be made within three years of the Bill receiving Presidential assent. The order made by the President shall be laid before each House of Parliament for their approval.
The model proposed at present involves three types of taxes Central GST (hereinafter “CGST”), State GST (hereinafter “SGST”) and Inter-State GST (“IGST”). The CGST and SGST would be levied simultaneously on all transactions where the seller as well as the purchaser are located in the same State. In case of inter-State transaction, SGST is not levied instead IGST is levied. CGST as well as SGST are levied on the basic value of the product unlike the present system in which State VAT is levied on the price inclusive of Cenvat. The taxes are charged by the seller from the buyer at the respective rates and deposited with the Centre or the State as the case may be.
Illustration: A is a dealer of goods in Karnataka which have not been exempted from taxes under the GST list. The rate of CGST is 12% and the rate of SGST is 8% and the goods are being sold to B who also resides in Karnataka. The value of the goods being sold is Rs 100 hence, A collects Rs 12 as CGST and Rs 8 as SGST. He is required to pay Rs 12 to the CGST account and Rs 8 to the SGST account though he need not actually pay the amount in cash, he can set it off against the CGST and SGST that he has paid on his purchase of some other goods, say inputs. However, the credit for one type of GST cannot be used to set off the other type of GST.
Under the proposed model, the Centre would levy IGST which would be the cumulative cost of CGST and SGST on all inter-State transactions. The IGST model helps in maintenance of an uninterrupted input tax credit chain on inter-State transactions and ensures creation of a self-monitoring system. The idea is that all inter-State dealers would be registered online and hence, compliance level will improve substantially.
GST would affect the powers of both the Centre and the States and their relations as well as the Lists in Seventh Schedule and hence, introduction of the model requires an amendment to the Constitution and the Bill would have to be passed by Parliament and ratified by one-half of the States in accordance with the procedure provided under Article 368.
Criticism of GST and challenges in its implementation
In spite of the noble objectives behind introduction of the GST Scheme, there are shortcomings in the scheme itself not to mention the practical difficulties in implementation of the scheme which makes the success of such a scheme questionable. The Thirteenth Finance Commission which dealt with the topic of goods and services tax outlined the issues that most State Governments had with GST. The States which had higher tax rates were apprehensive that they might be at a loss when a common tax rate is introduced for the whole country. States would also suffer losses due to abolition of CST as the taxes which they received from the manufacturing sector would be substantially reduced. The low income States with small consumer bases were fearful that they might end up being extremely dependent on the Centre and the appropriation of tax revenues might not be in their favour. It was also argued that the proposed scheme would result in a vertical imbalance in favour of the Centre which would have at its disposal a tax base which had hitherto been unavailable to it.
The Empowered Committee has expressed optimism about GST increasing the revenue for the Centre and States. Most of the existing taxes will be subsumed by the GST and multiple taxation would thus be avoided but the loss arising out of this will have to be compensated by the widening of the tax base. The tax rate under the proposed GST would come down but the number of assessees are expected to increase by five to six times. Hence, the overall revenue would be benefited by introduction of GST. The task force which had been constituted by the Thirteenth Finance Commission estimated that India will gain $15 billion a year by implementing GST as it would promote exports, raise employment and boost growth. The GST in Canada is similar to that proposed to be introduced in India and its introduction in Canada resulted in a 1.4 per cent increase in the GDP of Canada. This is suggestive of the potential benefits of GST for the Indian economy.
The States have also voiced their concerns about loss of their autonomy due to imposition of a common tax rate for the entire country. They fear that they would lose their tax leverage. The demarcation of powers between the Centre and the States gives the States power to independently impose taxes in their own domain. States take into account factors such as, socio-economic and political scenario in the State as well as the revenue requirements of the State while deciding tax rates and tax base. They would lose this flexibility under the proposed GST model.
States with high tax rates oppose the scheme because they foresee huge revenue losses arising due to implementation of a common low tax rate and demand adequate compensation for the same. States have also demanded that implementation of GST by States be made optional and they be allowed to adopt GST at their own convenience. The States want harmonisation of all tax returns, assessment and audit procedures using a comprehensive technology based infrastructure which would keep a record of all inter-State transactions.
A robust IT infrastructure would form the cornerstone on which the entire GST structure is proposed to be built. It would play a special role in implementation and management of IGST. The registration of dealers online based on their PAN numbers as well as keeping track of all inter-State transactions is a major practical obstacle in the implementation of GST. The transaction details need to be maintained on a common portal as IGST is collected by the Centre and later apportioned to the States based on the point of sale. In case of VAT the Centre had a broad IT infrastructure in place for Cenvat but adequate IT infrastructure is a troubling issue for the States even in VAT system. Collection of CGST can be taken care of for the time being by the Centre’s online tax payment system called Automation of Central Excise and Service Tax (ACES) by making required changes to it. However, computerisation and building adequate IT infrastructure for the States where such infrastructure is not present is a big challenge. The infrastructure facilities of the Centre and the States need to be tied up and the existing Tax Information Exchange System (Tinxsys) should be put to this use and upgraded to serve the needs of GST till a new independent structure is created.
The GST model works on the destination principle, that is, goods and services are taxed in the States where they are sold or rendered respectively. This makes the States fearful of losing revenue as they would not be able to charge taxes on manufacturing. States have pressed the demand for exclusion of purchase tax from GST which provides considerable revenue to foodgrain producing States and mineral rich states. Purchase tax is the same as sales tax except it is deposited with the State Government by the purchaser instead of the seller. The goods, mainly foodgrains, on which purchase tax is levied are exported to other States. So the burden of the tax is borne by the purchaser belonging to the other State and this transfers the tax burden from the population of the manufacturing State to the population of another State. Thus, the States are opposed to inclusion of purchase tax in GST. The Central Government has assured the States that in case purchase tax is included in GST, adequate and continuing compensation would be provided to the affected States and at present the matter is being discussed by the Central Government.
A single tax rate would make taxation extremely simple, however, the Empowered Committee in India has recommended adoption of a two-rate structure, a lower rate for the necessary items and a standard rate for goods in general. There will also be a special rate for precious metals and certain goods would be exempted from GST. There existed an exempted list and list of goods of local importance under VAT and the Central Government at present is considering whether or not the same should be retained in the exempted list under SGST and whether a similar approach should be followed for CGST.
The tax rate at which the GST model would produce the same revenue as the present taxation structure is called revenue neutral rate (hereinafter “RNR”). If the GST rate is above RNR, it will result in increase in overall prices and the consumers would be burdened by the inflated costs whereas, if the GST rates are below RNR then, it would create a strain on the economy as the Central and State Governments would not have enough revenue to be spent on the development projects. The RNR is unique for each State hence, no one rate of GST can be decided which would ensure equilibrium and strain on either the consumer or the economy would be created in most of the States. Some States have suggested that this situation can be avoided by providing a band of GST rates, similar to the practice followed in the European Union. However, this disparity in rates can create undesirable consequences by creating an opportunity for tax arbitrage and incentivising clandestine inter-State trade.
GST is based on an input tax credit system which is very difficult to implement especially for inter-State transactions. It has been proposed that the following taxes would be kept out of the ambit of GST:
- Levies on petroleum products.
- Levies on alcoholic products.
- Taxes on lottery and betting.
- Basic custom duty and safeguard duties on import of goods into India.
- Entry taxes levied by municipalities or panchayats.
- Entertainment and luxury taxes.
- Electricity duties/taxes.
- Stamp duties on immovable properties.
- Taxes on vehicles.
Consequently, the taxation on the above products would continue as is currently prevalent. This means that these products would continue to suffer from the negative impact of tax cascading and their prices would continue to be inflated. It would also come in the way of ensuring the competitiveness of these products in foreign markets.
Another concern which the States have voiced is that of the common threshold limit of exemption being too low and the possibility of inclusion of several small entrepreneurs in the tax base. Tax regimes generally have a threshold limit of annual turnover below which all businesses are exempted from paying taxes. The reason for introduction of threshold limit is to protect the interests of small traders and also because of the practical difficulty in administering taxes at such a small scale. The compliance and administration costs of such taxes are higher than the revenue generated out of their collection. At present, States specify their own threshold limits under the State VAT Acts. The Empowered Committee in its report recommended a common threshold limit for the sake of harmonisation of the tax structure. It recommended Rs 10 lakhs as the threshold limit for SGST for both goods and services with compensation to those States which lose out on revenue because of the threshold limit becoming higher. Rs 1.5 crore was recommended as the threshold limit for CGST for goods and while no specific limit was given for services it was recommended that the limit for services also be kept sufficiently high to protect the business interests of small traders.
The Central Government has addressed most of the concerns of the States and other stakeholders but there still remain obstacles in the passage of the Bill and practical difficulties in its implementation. While the Government and the Empowered Committee are trying to reassure the States about protection of their revenue and promise them compensation for the lost revenue, the real problem it seems is not the GST model but the political dynamics at the Centre and State. At present, the Bill which has been passed by parliament is facing severe opposition from the opposition parties including Congress which during its tenure had introduced the first GST Bill and based on whose demands the Bill has been sent to a Select Committee. The Standing Committee created for the 2011 Bill also looked into the matter in great detail and there is not much difference between the model proposed to be introduced by the 2011 and 2014 Bills. Hence, such a demand seems to be frivolous and politically motivated. Sending the Bill to a Select Committee has elongated the process of passage of the Bill and foiled BJP’s plans of getting the Bill passed by Parliament in the budget session itself. The Bill being a Constitutional Amendment Bill and not a simple Money Bill for imposition of tax, the legislative procedure appears to be a long drawn one.
The Bill itself provides for only a skeletal outline of the proposed scheme with many of the major decisions being left to the GST Council proposed to be set up under the Bill. The real challenge in ensuring that GST achieves the objectives that it has set out to achieve is to ensure that the almost perfect model which has been outlined is actually put into practice. With an incomplete IT infrastructure and uncertainty about the common tax rate to be imposed, the extent and manner of compensation to the States, the Rules governing implementation of GST, the viability of an input tax credit system and the nodalities of the dispute resolution mechanism, the Bill leaves a lot to be decided by the GST Council which makes the success of the model quite uncertain.
The Bill contrary to what the States believe does not go against the principles of fiscal federalism as it provides the Centre and the States with concurrent powers to make laws in relation to GST and a say in the decisions of GST Council. Even if the argument of the States about the Bill being opposed to fiscal federalism is accepted, what cannot be denied is that the move is not aimed towards filling the cofers of the Centre but to improve the country’s economy and the condition of consumers. Under such circumstances, it is the duty of the States to place the well-being of the residents of their territory above their own autonomy and cooperate with the Centre even if it involves compromising on their federal powers.
The future of GST in India and its success is thus, to a large extent dependent on the GST Council’s decisions. If the GST Council with its State Government representatives, succeeds in reconciling the differences between the States and reaches a consensus on the issues it is required to deliberate upon then, it would undoubtedly unfold one of the greatest reforms in the field of indirect taxes in India with the repercussions being felt by the economy, trade and consumers alike. The task of balancing the interests of the States and the Centre and at the same time ensuring that the powers conferred and the decisions taken do not in any way encroach upon the autonomy of States or compromise the federal structure of the Indian Constitution is a difficult one. However, this task if performed successfully holds great promise for the future of the country’s economy.
*IInd year student, National Law School of India University (NLSIU), Bangalore.
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