Role of CA in GST - bcasonline.org of CA Pre-GST Period Post-GST Period. 3 ... Post implementation...

Role of CA in GST- CA Madhukar N Hiregange

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Pre -GST

Post -GST

Role of Chartered Accountant

Role of CA

Pre-GST Period

Post-GST Period

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Role as per Model GST Act, 2016

Overview Operational Consultancy

Network support & Infra.

Accounting & Taxation

Compliance requirement

Transitional Support Sr.

Centre/State Support Sr.

Audit & Assurance

Pre-GST Period1. Role as pre M-GST Act2. Overview3. Operational Consultancy4. Network support & Infra.5. Accounting & Taxation 6. Transitional Support Sr.7. Centre/State Support Sr. 8. Global Opportunities

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• Access to Business Premises

•Appearance by Authorised Representative

• Special Audit

• Accounts and other records

Section 42

Section 50

Section 64

Section 86

Section 126 – Disclosure of Information by Public Servant

Pre-GST Period1. Role as pre M-GST Act2. Overview3. Operational Consultancy4. Network support & Infra.5. Accounting & Taxation 6. Transitional Support Sr.7. Centre/State Support Sr. 8. Global Opportunities

Being in a position to analyse the industry impact considering the global and Indian situation of the product / service;

In case of unintended hardship to some sectors- representation to the drafter would be in order as the level of listening presently is very high;

The clarity on the major impact on the client under GST due to in-depth understanding of the business; This presently service offering would provide the client with important information to plan the way forward under GST. This could be done as it is to be validated after GST law is in place;

Being part of the core team of client for transiting into GST smoothly without business disruption as a knowledge advisor;

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Pre-GST Period1. Role as pre M-GST Act2. Overview – Key Areas3. Operational Consultancy4. Network support & Infra.5. Accounting & Taxation 6. Transitional Support Sr.7. Centre/State Support Sr. 8. Global Opportunities

• Systems at client workplaces soas to provide appropriate adviseon migrating to better systems/ERP or suggest modification tomake the existing systems GSTcompliant;

Understanding legacy tax

• For example supporting in decisions on:Closure/ reduction in godowns and branches;direct sale through e- commerce; evaluationof the working with C&F agents; in house/outsourcing the distribution function tologistic companies; sourcing inputs at lowestcost within shorter time; linking to the ERP ofthe customer etc.;

Assisting in preparation of a strategic plan for procurement and marketing systems of clients needed

under GST.

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Changes in accounting software and internal control systems to suit GST. Test and confirm the robustness;

GST awareness at initial stages and training for management, staff, vendors of clients.

Vetting and suggestion to modify agreements/contracts/ major purchase orders overlapping orsupplies to be made in GST regime; Ensuring that thecredits in the past are examined for their eligibility andthose missed are availed. The reconciliation of thecredit as per books to the returns before GST isimplemented can be a value added activity. This wouldinclude validating the last return;

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Ensuring that the claim of credit on stock in hand is maximized by ensuring purchasing with excise duty paying documents as well as proper stock recording especially with job workers and agents and ensuring well thought of stocking policy;.

Reviewing the various business transactions to examine whether closing out the transaction in the pre GST or post GST period is advantageous;

The need to train the officers in the Companies, other professionals, traders and tax officers is real as the law is still developing. This could be a learn while you learn philosophy;

The students of CA- the future CAs would also require to be taught the new law to enable them also to contribute in future;

Many CAs have specialisation in information technology and some even hand on consulting skills in ERP environment. These skills could ensure that the client would get his IT in order;

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• Revisit the pricing strategies with the distributors

• Renegotiate (if any) the pricing with suppliers

Pricing

• Alignment of all major contract terms and tax clauses with GST

• Discounts terms to be specifically brought out in the contractsexecuted with distributors

Review of contracts

• Making representation for lower rate of GST, taxability ofpromo products issued free

Representations

• Maintaining detailed registers of supply and procurements, inputcredits

• Timely filing of monthly and annual returns

Compliance and documentation


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• Tracking GST developments and creating awareness on GST

GST developments

• Mapping impact of GST on current supply chain and suggestingmodifications from GST perspective

Impact on supply chain

• Identifying impact on financials, working capital, credit chain,concessions, and suggesting tax planning options

Impact on business and finance

• GST awareness trainings, review of compliances, creation ofmanuals and access to GST updates/resolution to queries

Post implementation compliances

• Changes to ERP modules, MIS reports, statutory compliancesupport, and ongoing trouble shooting support

ERP Updation


Synchronising IT Systems & Old

data

Strong Management Information

System

System Reconciliations

Data Integration between Centre

& States

Automation of returns and other utilities at Centre as well as States

Updating Amendments in

IT Systems

Data management for State Jurisdiction

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Treatment of Incentives / Discount

Process Documentations & Accounting Manuals

Branch Transfers

Budgetary Controls

Control & Dispute Settlement

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Deregistration from Existing Laws

Managing Pending Litigations

Review & Certification of Stock on date of transition

Knowledge Sharing & Capacity Building

Credit Analysis and Utilization

Comparative Valuation Under GST

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Representation - unintended hardship to sectors

Conscripting Legislation & Rules/ Procedures

Monitoring Transactions & Revenues

Cross –verification with Other Acts

Training & Education

Fixing Rate Based on RNR and Review

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Pre-GST Period1. Role as pre M-GST Act2. Overview – Key Areas3. Operational Consultancy4. Network support & Infra.5. Accounting & Taxation 6. Transitional Support Sr.7. Centre/State Support Sr.8. Global Opportunities

Tax Advisory Services

International Research Issues

Knowledge Process

Outsourcing

Information & Knowledge Sharing

Capacity Building Services

Technology Support Services

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Pre-GST Period1. Role as pre M-GST Act2. Overview – Key Areas3. Operational Consultancy4. Network support & Infra.5. Accounting & Taxation 6. Transitional Support Sr.7. Centre/State Support Sr. 8. Global Opportunities*

Post-GST Period1. Overview – Key Areas2. Compliance requirement3. Audit & Assurance

There would a period of uncertainty and need for someone to confirm the myriad issues arising. The internet (Google) at such times may not be effective as too much of inaccurate/

incorrect suggestions in the initial stages are expected. The proactive professional handholding and quick response may not only ensure continuation of the clients business but enable them

to take advantage of the changes in the business structures;

These are likely to result in

denial of registration,

interruption to do business,

loss of eligible credit,

old law risks and exposures carried

forward,

inadvertent non-compliance in GST.

Gap Analysis -

In the initial stages, there may also be gaps in knowledge of GST at various levels in the organisation.

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Regular online service to the functional head of

clients business;

Assisting in the filing of the 1st return;

Review the compliances in

transition - disputes in GST would come normally after 3-4

years and at that time, rectifying past errors

would well nigh not be possible;

A one time comprehensive review

to ensure GST compliance;

Regular review and reconciliation on

credit matching and recovering credits lost form the vendors in

case of payment made on gross would also

be required;

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Once GST stabilises, the focus would be more on compliance which means a regular internal audit of GST;

The GST audit by CAs in the year 2018 would be a watershed year for the profession to demonstrate that we as CAs are competent and knowledgeable;Also to assure that revenue department that there is no need of invasive investigation or audit by tax officers;

Routine tax assignments for payment and filing of returns would see a spike at least in the initial stages of uncertainty;

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It is true that if one can avoid a dispute in tax it is better.Therefore a preventive exercise of early correction/ disclosurecould avoid or mitigating the disputes allowing clients toconcentrate on their core activities;

In case of dispute look at the possibility of passing on theimpact where credit is available as an option. If not possiblethen support in making replies based on fact as well as legalprinciples.

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Compliance Under State Jurisdictions

Registrations Under New Scheme

Online Filing of Returns for each State

Evaluation of Tax Liability with Credit Set-off

Statutory Compliances & Record Keeping

Filing of Declarations

Export Management

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Internal Review of Change

Management

Internal Controls &

Internal Audit of

Compliance

Checklist for Statutory

Audits

Assistance in Departmental

Audits

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Questions?- [email protected]

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Role of CA in GST - bcasonline.org of CA Pre-GST Period Post-GST Period. 3 ... Post implementation...

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Transcript of Role of CA in GST - bcasonline.org of CA Pre-GST Period Post-GST Period. 3 ... Post implementation...