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Building the World’s Biggest, Most Complex Tax System: GSTN Chairman in an Exclusive Interview

Building the world’s biggest, most complex tax system.



Mountains protrude through clouds in this aerial photograph taken above the Himalayas in Jammu and Kashmir, India. (Photographer: Prashanth Vishwanathan/Bloomberg)
Mountains protrude through clouds in this aerial photograph taken above the Himalayas in Jammu and Kashmir, India. (Photographer: Prashanth Vishwanathan/Bloomberg)

A team of 46 people, located in an office near the Indira Gandhi International airport in India’s capital city, are undertaking a task of Himalayan proportions.

They are working to set up an IT network that will connect over one crore taxpayers with all the states and the centre, banks and RBI and tax authorities. It’s a gigantic task and now a race against time. Because if they are not ready by April 1, 2017, India’s transition to a Goods and Services Tax will be non-event at the least, a chaotic, failure at the worst.

In this exclusive interview, BloombergQuint’s Menaka Doshi asks GSTN Chairman, Navin Kumar about the challenges in getting India GST-ready.

What is GSTN?

I would like to start by asking you describe to me GSTN’s mission. I understand it was a not-for-profit body that was set up in 2013, with the explicit purpose to set up IT infrastructure for GST in India. 

Yes. That’s right. It’s a not-for-profit, non-government, private limited company promoted by the central and state governments. And the specific mandate of the company is to build the IT infrastructure and the services required for implementing GST. And these services will be made available to all stakeholders such as the central tax department and the tax departments of all state governments, the RBI, the banks etc. and of course the taxpayers.

Can you take us through the various steps you have gone through already in building out this network and where we stand today in terms of GSTN’s preparedness?

You see the last year, that is 2015, we had called for offers from IT companies to come to us to carry out this task of building the common GST portal, all the applications that will run on the portal, to bring the hardware, to load the applications on the hardware and to run it and operate it for five years. So at that time we had received offers from all the big companies like TCS, Infosys, Wipro, Microsoft and Mahindra. So all of them came and we selected Infosys on the basis of a national bidding process. So, November 2015 we awarded the contract to them and at that time we asked them to go ahead with application development and we asked them to wait for our signal for placing orders for the hardware. Since November they have been working on the software part. We were waiting for the Rajya Sabha to pass the Constitutional Amendment, which has happened now, so we have given them the go ahead for placing orders for the hardware. So this is where we stand today.

We were waiting for the Rajya Sabha to pass the Constitutional Amendment, which has happened now, so we have given them the go ahead for placing orders for the hardware.
Navin Kumar, Chairman, GSTN

When will the GST Network be Ready?

Could you share some more detail with us on the process of putting in place the hardware, in terms of both timelines and cost, and also in terms of software preparedness, where things stand today?

You see, so far as the financials of the project are concerned, the total cost is around Rs 1,380 crore, which includes the cost of hardware, software and the operations for five years. So, now that we have given the go ahead for hardware, they will place the order for the same and we expect the entire hardware is to be imported, and this will be installed and tested and made ready to accept the software, and by December it will be ready. By that time, the software, further work on that will continue. We hope to start testing the software from October. And in December it will go on to the hardware and then we will start the beta run in February. So that is the schedule, so that you have everything ready before 31st March.

Migration of existing taxpayers of VAT which number about more than 65 lakh and about 20 lakh of service tax payers and about 3-4 lakh of central excise taxpayers - their migration starts sometime in October and it will go on until February.
Navin Kumar, Chairman, GSTN
When you say that you hope to start testing the software in October, will you be testing this software in terms of converging the current VAT, service tax, central excise registrations and migrating them to a GST registration, from various states point of view?

Yes. That is also a part of the task that we are going to perform. See, software development is one part. Migration of existing taxpayers of VAT which number about more than 65 lakh and about 20 lakh of service tax payers and about 3-4 lakh of central excise taxpayers - their migration starts sometime in October and it will go on until February. Four months, because there we would be asking all taxpayers to come to our portal and fill in the information. We already have the numbers and essential information regarding the companies names or their constitution. That we have. But rest of the information they are supposed to fill up. So this will happen between October and February.

Do you have the systems in place for this to happen already or will they be built out in the months to come and you would be ready only in October?

No. That work is going on but it will be ready this month itself. We came to Bangalore to discuss that only, the progress on that. We had a meeting with Infosys today (Friday, August 5). So that work is going on it will be ready on time. Because that software also has to be tested and only then it will go live, most likely on 2nd October.

 
GSTN will start migration of over 90 lakh indirect tax payers to GST on October 2
What about new registrations?

New registrations under GST will be from the date GST is to be rolled out, the target date, that is 1st April. So from 1st April, new registrations will begin and they will be registrations under GST directly.

Have you have tested the robustness of the software and the back-end, to be able to deal with 90 lakh migrations and then of course several lakh more new registrations?

We have not tested yet, but we are going to test it. Because as I told you, on the migration part the software is ready. So, we are starting testing that software now. But it will be available for taxpayers to come and enter their information starting from October. And so far as the GST part is concerned that software is still under development and as I told you, that testing will start from October-November-December. We have scheduled different parts for testing, starting from October. And from February the entire thing will be ready so we will have the beta run.

GSTN is also building the back-end infrastructure for 19 states
Mr. Kumar, the government yesterday (Thursday, August 4) released a proposed timeline for the implementation of the GST, in which it suggested that the GSTN front-end and back-end for 17 states will be ready by December 2016, and for stakeholders obviously by April 2017. Now what you have just described to me in terms of the software development, the migration, the new registrations...is that what the government is referring to when it says front-end and back-end for 17 states by December or is that a separate process that you have to work on parallely?

That is different. You see what we are doing is the front end, that is where the taxpayers will come, they will register themselves, they will file the return and make tax payment. That is the front-end.
Back-end is the part where, once we get all the data, we will pass it on to the respective tax authorities. And they will do their tax administration functions like assessment and audit and adjudication, things like that. That is called the back-end.
So normally one would expect the states to develop that. But, in fact 19 states approached us saying that you please help us with it. So we have agreed to do that for 19 states. So that work also we are doing and that will also simultaneously be ready.

The other states intend to do it on their own?

They are doing it on their own and they have all made progress so we hope all of them will be able to manage before the 1st of April.

Do you anticipate any challenges given that 19 states will be using GSTN to do it whereas the others will be doing it on their own?

There will be no challenge because you see so far as we are concerned we are looking at the front-end. All the data is there. Now, after we pass on the data to each tax authority, it is up to them how they keep the data. They are not going to send it back to us. So, it is entirely up to them. But what we have done, we have shared with these states, what we call model one, model two states. Model One states are those who are building the back-end themselves. Model Two are those for whom we are building the back end. So the Model Two back-end processes we have shared with all the Model One states. It is up to them to adopt it. We have suggested if you adopt it there will be uniformity, but even if you have your own processes it would not have any problem.

GST Front-End

  • Migration of over 90 lakh existing indirect taxpayers to GST network will begin in October 2016
  • New registrations will begin when GST is implemented, in April 2017
  • Software to enable migration is being tested right now. Software for new registrations is under development
  • Hardware orders for GSTN network will be placed now, after the Rajya Sabha passed the Constitution Amendment Bill


GST Back-End

  • GSTN is building the back end for 19 states.
  • Remaining states prefer doing it themselves.

The Challenges?

Can you give me an idea of how challenging this process has been? 

There are many challenges. The first challenge is that it is an entirely new thing for the country because it is very different from the current tax systems for VAT or central excise or for service tax. Also these are all value added taxes but since all of them are coming together, so what is emerging now will be entirely different from whatever the current experience. Therefore, this is a big challenge, it is a new thing.

The second is the size. Until now the largest taxpayer base among indirect tax was with the Central Board of Excise and Customs (CBEC), where they had 20 lakh service tax payers and the states had 5-7 lakh. Now today we will be looking at something like one crore taxpayers (under GST). So the size of the system is humongous. And therefore we have to be very sure that the system that we prepare is efficient enough and robust enough to take this load and it is efficient enough to deliver very good experience to the users.

The third one, as I said, this is a new thing. Therefore, we have to familiarise the tax officials as well as the taxpayers with the new system, and it has two parts. One part is familiarity with the law, the other part is familiarity with the IT system. The law part comes with the revenue ministry, the finance, revenue departments, they are organising training camps. We are also assisting. For that we have drawn up a program. A series of training programs for tax officials. And we will be collaborating with all the trade bodies for disseminating information and training material to the taxpayers through them. So this is the program.

There are many challenges, it will be perhaps the most complex systems that the world has seen. One of the largest tax systems that the world has seen.

It will be perhaps the most complex tax systems that the world has seen. One of the largest tax systems that the world has seen.
Navin Kumar, Chairman, GSTN

How Should Businesses Prepare?

Mr. Kumar, from a business point of view what would business expect in how their interface will change? So if you can, in very simple terms, describe for me how currently business interacts with the variety of central and state indirect tax authorities and how that interaction or interface will change once they have to approach GST through the GSTN system?

Today what happens, if you look at any of the three major indirect taxes which are being subsumed under GST, you see it is not entirely in the electronic form. In many states, a good number of filings take place on a manual basis. Although all states now have a computer system, but not everybody is required to file in electronic form. So that is one big difference that will happen. Because GST, whether big or small, every taxpayer is supposed to register himself and file his returns in electronic form. So this will be one change for the taxpayers.
Now, this is not a very big challenge because those who have started electronic filing under VAT or service tax, they would know how to handle the system. And for the smaller taxpayers, through our study we have found, incase of VAT, that these smaller taxpayers use the services of tax consultants to file the returns and these tax consultants are quite savvy. They won’t have much of a problem.
And in order to facilitate small taxpayers to file the return or interact with us we are encouraging the private sector come up with mobile applications that would enable smaller taxpayers to file returns easily. So this is the main difference that will come.

There will also be a difference in the manner in which the returns are filed. Because today what is that every taxpayer files returns by giving details of sales and purchases. On the basis of this return, tax credit is allowed. Ideally, the tax officer must look at the returns filed and verify whether the input tax credit is claimed rightly or not. But because of the large numbers (of taxpayers) it is not possible. So that happens only during audit or assessment, in which 2-5 percent of taxpayers are taken up under audit or assessment. So, there is an impression, and in audit it has been found, that large number of input tax credit claims are inflated. So on our system (GSTN), the input tax credit will be verified online. So, for the taxpayers it will be good because online verification will be there and they will get the credit immediately. And those who are trying to take inflated credits, that will be prevented.

Another difference is that taxpayers are being asked to file only the return of sales, under GST. So they will file the sales returns by 10th of the month. This is in the law (Model GST Law) is coming and that has been put on the website. By 10th they will submit their sales returns. Then this sales data will be populated in the purchase returns of the purchasers. So they (purchasers) don’t have to file, this will go into their account. They only have to look at it and say yes this is correct. If they find it is not correct, they will make the correction. So this input tax credit will be taken care of automatically because they can now decide, that yes this is the amount of tax I have paid or I have collected. So from there on the matching of input tax credit will become easy and it will be 100 percent correct.

In order to facilitate small taxpayers to file the return or interact with us, we are encouraging the private sector come up with mobile applications that would enable smaller taxpayers to file returns easily.
Navin Kumar, Chairman, GSTN
Like you pointed out, this is probably the world’s largest and most complex tax system that’s being put in place. We are a country that is frequented by power shortages, lack of bandwidth or internet connectivity. In the face of very simple challenges of this nature, do you think it will be easy or difficult for small business to comply with GST processes? Big companies may be able to overcome such challenges, but for small businesses to be able to seamlessly connect with the GSTN network, whether they do it directly on their own or they do it through consultants, will be tough?

I already mentioned that for these small taxpayers we are encouraging the private sector to come up with small apps that they can run on mobile. Now in India the mobile population is very high, you will find on every street, everybody has a mobile. So we think that will really help those small taxpayers who do not want to work with tax consultants. Consultants of course have connectivity, so there is no problem. We have also decided to put up apps which they can download from our system and use, for uploading data to our system. And those will be available on mobile also.

It is expected that the first year or two implementation of GST are the toughest years. Because that is when you see volatility in prices or when you see the tax systems trying to cope with the influx of registrations. What do you expect year one and year two to be like?

See, I am not the right person to answer this question because this is a question for financial analysts or for economists. But what I can tell you is that, in the first two years we will also have issues because when you run such a large system, there would be some problems that will come up. But our effort is to build a system, such that whenever any issue is flagged we should be able to resolve that within a defined period of time. So the system is available on time and the response is fast.

What advice would you give to businesses, both big and small, traders and individuals, that will need to register on the GSTN network? How should they start preparing for the transition to this new tax, GST?

Ya businesses have time now. We are in July, and this tax will come from 1st of April. So during this time they need to (prepare). All the businesses are today filing returns under the prevailing tax regime and for that they have made arrangements. Those arrangements would have to be modified in the light of the new processes and law. So we have called agencies like SAP and Oracle and all the accounting software people and we have told them that they should start working on modifying their software so that their clients can make the filing of tax returns under the GST regime. So I believe that these companies are already at it. It is a challenge because the time is not very long. But, I think they will be able to do it.

We have called agencies like SAP and Oracle and all the accounting software people and we have told them that they should start working on modifying their software so that their clients can make the filing of tax returns under the GST regime.
Navin Kumar, Chairman, GSTN

Is April 1, 2017 a Realistic Deadline?

Do you believe April 1, 2017 is a realistically achievable target for the implementation of GST. Would you have preferred it if there were some more time available for systems and infrastructure to be in place for a smooth transition to this new tax?

I can only talk about the IT part and we will be ready by 1st of April. Because we have started early. In fact, we have started working on this in December 2014, that is when we appointed our consultant to draft the project and what all will go into the RFP (Request For Proposal - to build the network). We had at that time discussed with the IT industry also, and taken their suggestions. So we had the time to make preparations, and we will be ready by 31st. I think so far as we are concerned it is quite practicable.