“Ease of doing business” via. QRMP and IFF

Intending to achieve “ease of doing business”, the GST council, in its 42nd meeting, proposed a QRMP and IFF scheme. Every registered taxpayer having an aggregate turnover up to Rs.5 crores now has an option to either opt for QRMP and IFF scheme or continue filing monthly returns, i.e., GSTR1 and GSTR3B. This new scheme has provided much-needed relief to all the small registered taxpayers most affected by the ongoing pandemic.

The QRMP or Quarterly Return filing and Monthly Payment scheme were first introduced on January 1, 2021. In this scheme, the registered taxpayer is required to file GSTR1 and GSTR3B quarterly. Also, with the quarterly filing requirement, the registered taxpayer has to file an IFF or Invoice Furnishing Facility wherein he would declare his b2b invoices, debit, and credit notes every month.

This is a particularly peculiar scheme that not aims to create ease of doing business and facilitates those registered taxpayers. They might have lost their eligible ITC trying to comply with section 36 of the Central Goods and Services Tax Act, 2017 because their suppliers were quarterly taxpayers.

The registered taxpayer has to opt for this scheme anytime between the start of the second month of the last quarter till the end of the first month of the quarter. For example, the registered taxpayer wants to opt for QRMP scheme for October to December 2021 quarter; then the timeline would be from August 1, 2021, to October 31, 2021.

Upon opting for the QRMP scheme, the registered taxpayer would have to file IFF for the first two months of the quarter, followed by a quarterly GSTR1 incorporating any missed out invoices from the earlier period. In each month, the registered taxpayer has to deposit his share of liability in PMT06 either by opting for a fixed payment which works out to be 35% of the previous month’s liability or make a self-assessment of the relevant period’s net liability.

At the end of the quarter, the registered taxpayer would be liable to file a quarterly GSTR3B, wherein he would declare his quarterly outward liability as well as his eligible credits for the quarter. This would result in his net liability for the quarter. Now, he would be eligible to claim the previously paid liability through PMT06.

Hence the registered taxpayer would be liable to make the payment, if any, for only the balance liability after considering the costs through PMT06 of previous months. If, in any case, there’s a surplus of payment, then the same could either be claimed as a refund or used in the subsequent periods.