季度申报与按月缴税 | QRMP 计划

中央间接税与关税委员会（CBIC）根据商品及服务税（GST）推出的 QRMP 计划，旨在帮助年营业额在 5 亿卢比以下的小型纳税人。QRMP 计划允许纳税人按季度申报 GSTR-3B，但需每月缴纳税款。

1. 季度申报与月度缴税（QRMP）计划概览

2. 什么是 QRMP（季度申报与月度缴税）计划？

GST 理事会在 2020 年 10 月 5 日召开的第 42 次会议上建议，对于上一财年年度总营业额不超过 5 亿卢比的纳税人，应允许其按季度申报GSTR-3B和 GSTR-1。但税款仍需通过缴款单按月缴纳。该计划自 2021 年 1 月 1 日起实施。

根据 GST 理事会的建议，政府推出了新的 QRMP 计划，自 2021 年 1 月 1 日起用于 GST 申报。该计划允许符合条件的纳税人按季度申报 GSTR-1 和 GSTR-3B。但 GST 仍需按月缴纳。

3. 谁有资格选择 QRMP 计划？

并非所有纳税人都可以根据 QRMP 计划进行申报。纳税人需满足以下条件方可选择该计划：

1. 上一财年及本财年的总营业额不得超过 5 亿卢比。如果本财年内任何季度的总营业额超过 5 亿卢比，则该纳税人从下一季度起将不再符合 QRMP 计划的资格。

例如：如果某人在 7 月至 9 月期间的总营业额超过 5 亿卢比，则该人从 10 月开始的季度起，将不得再根据 QRMP 计划申报。

2. 要选择 QRMP 计划，纳税人必须在选择该计划之日已完成任何季度的最后一次 GSTR-3B 申报。（后续将详细讨论）

因此，新注册的纳税人或已退出简易征收计划（Composition Scheme）的纳税人均有资格选择 QRMP 计划。

4. 如何行使 QRMP 计划的选择权？

4.1 针对 2021 年 1 月至 3 月季度的现有注册纳税人

For all registered persons having aggregate Annual Turnover (Turnover of all PAN during FY 2019-20), and those who have filed GSTR-3B for the month of October, 2020 till 30^th November, 2020, the system has automatically put it under QRMP Scheme. 

However, such registered persons may opt out of the QRMP scheme, by 31^th January, 2021 for the quarter of January to March, 2021.

因此，许多注册纳税人已在其注册手机号码上收到来自 GST 门户网站的以下信息：

“尊敬的 GSTIN 用户，根据 QRMP 计划，您已被默认设置为从 21 年 1 月至 3 月起按季度申报 GSTR-1 和 3B。如需更改，请访问 www.gst.gov.in”

Further, those taxpayers who have not filed GSTR-3B of October, 2020 till 30^th November, 2020, are not put under QRMP scheme by system automatically. Therefore, they can file their GSTR-3B and opt for QRMP scheme by 31^st January, 2021.

4.2 针对新注册纳税人及未来季度

选择 QRMP 计划的功能可在 GST 门户网站在线操作。登录 GST 门户后，通过“服务 (Services) > 申报 (Returns) > 选择季度申报 (Opt-in for Quarterly Return)”即可进行设置。

Every person who wish to opt for QRMP Scheme, should exercise the option at GST portal from the 1st of the second month of the preceding quarter until the last day of the first month of the quarter for which such option is being exercised. Accordingly, following are time limits for exercising option:

A person can opt in or opt out during the above mentioned period and final status as on last day of the first month shall be final.

5. How a newly registered person will opt for QRMP Scheme?

If a person obtains GST registration during 1^st Month of the quarter then he can opt for QRMP for such quarter by end date of such month. Otherwise, for the first quarter, such person is required to file GSTR-1 and GSTR-3B under regular scheme and he can opt for QRMP for the following quarter by the due date.

E.g. A person obtains GST registration on 15^th January, 2021. Then such a person can opt for QRMP scheme for January to March, 2021 quarter by 31^st January, 2021. However, a person obtaining registration after January, 2021 shall be required to file GSTR-1 and GSTR-3B till March, 2021 under regular scheme. He can opt for the QRMP scheme from April, 2021 onwards.

6. What is the frequency of GSTR-1 and GSTR-3B filing if a person opts out of the QRMP Scheme?

Once the registered person has opted for quarterly filing, he will have to continue to furnish his return under QRMP Scheme for all future tax periods, except in the following situations:

1. Till taxpayer becomes ineligible for furnishing return under QRMP Scheme, i.e., his aggregate turnover during the year exceeds INR 5 Crores.
2. A person willingly opt out of QRMP Scheme.

All persons other than opting for QRMP Scheme need to file GSTR-1 and GSTR-3B on monthly basis. Therefore, if a person was filing GSTR-3B on monthly basis and GSTR-1 on quarterly basis and he opts out of QRMP Scheme, then he will be required to file both GSTR-1 and GSTR-3B on monthly basis.

7. Are there any important points to be considered for opting in or out of QRMP Scheme?

1. Taxpayer can’t change his option for two consecutive quarters. The option selected in the current quarter will be set as the default option for the subsequent quarters.
2. If a taxpayer has saved some data in GSTR-1 of the same month then he can’t opt for QRMP scheme, but can opt after deleting the data from the GSTR-1.
3. If taxpayers opt for the QRMP scheme and not choose any option then both Form GSTR-1 and Form GSTR-3B will be required to be filed at quarterly frequency by default. However, Payment needs to be made every month for tax dues on monthly basis through a challan.

8. What is the New Invoice Furnishing Facility (IFF) under QRMP Scheme?

8.1 Issue under existing regime

In the existing scheme, the registered persons having an aggregate annual turnover of upto Rs. 1.5 crores during preceding year and current year are given an option of filing their GSTR-1 on quarterly basis. 

However, due to quarterly filing of GSTR-1 by such person, various registered buyers are not able to claim Input Tax credit of GST paid by them due to non-reflection of ITC in their GSTR-2A & GSTR-2B of such month. E.g., a person buys goods from a registered person, who has opted for quarterly filing of GSTR-1, in July, 2020. However, ITC in GSTR-2A of buyer shall reflect after September, 2020 (when supplier files his GSTR-1 for the quarter of July to September, 2020). Therefore, as per Rule 36(4), he will be entitled to take this credit in month of filing of GSTR-1 of supplier.

Such recipients of goods or services, including some big corporates or dealers, have become reluctant to purchase their goods or services from such small registered persons who have opted for quarterly filing GST Returns. Their cash outflow increases due to the non-reflection of their corresponding ITC in their GSTR 2A/2B. This scenario has made the filing of GSTR-1 on quarterly basis redundant.

8.2 Solution under QRMP Scheme

To overcome above difficulties, under the QRMP regime, an Invoice Furnishing Facility (IFF) is being enabled in the GSTN portal.

The registered persons opting for the QRMP Scheme would have an option to furnish the details of outward supply on GST portal on monthly basis.

For each of the first and second months of a quarter, such a registered person will have the IFF facility on optional basis 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. 

Outward supplies shall, however, not exceed the value of fifty lakh rupees in each month. It may be noted that after 13th of the month, this facility for furnishing IFF for previous month would not be available. 

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.

9. What is the Frequency of filing of GSTR-1 and GSTR-3B under QRMP Scheme?

It is not that under QRMP Scheme, both GSTR-1 and GSTR-3B are to be filed on quarterly basis. Under QRMP Scheme, option to file both returns are available on either Monthly or Quarterly basis. Every time a registered person is opting for QRMP scheme, he need to select whether he opt for monthly filing of return or quarterly filing. 

Following is the screen shot of dashboard appearing of QRMP scheme:

1. For monthly filing of return under QRMP Scheme:

2. For quarterly filing of return under QRMP Scheme:

10. What is frequency of filing of return for registered person migrating under QRMP Scheme from 01.01.2021?

For existing taxpayers who are by default put under QRMP scheme, system has set following frequency of return filing:

11. How to submit details of outward supplies in QRMP Scheme?

The taxpayers who opted for the QRMP scheme can use the Invoice Furnishing Facility (IFF) which allows quarterly GSTR-1 filers to upload their invoices every month. It can be use only when a taxpayer whose turnover is up to Rs.1.5 crore. 

Following points in mind before utilizing the IFF:

• The IFF can be utilized only for the first two months of a quarter.
• The invoices relating to the last month of a quarter are to be uploaded in the GSTR-1 return only.
• There is no requirement to upload invoices in GSTR-1 if the same has been uploaded in the IFF.
• The taxpayer has to submit the B2B invoice details of sale transactions (both inter-state and intra-state) along with debit and credit notes of the B2B invoices issued during the month.
• The total net value of invoices that can be uploaded is restricted to Rs.50 lakh per month.
• The details submitted in IFF will be reflected in the GSTR-2A, GSTR-2B, GSTR-4A or GSTR-6A of the recipients as the case may be.
• The Invoice Furnishing Facility will come into effect from 01.01.2021.

12. How to make monthly tax payments under the QRMP scheme?

The taxpayer has to deposit tax using form GST PMT-06 by the 25th of the following month, for the first and second months of the quarter.

Taxpayers can pay their monthly tax liability in following methods -

12.1 Fixed Sum Method (FSM) under QRMP

The taxpayer must pay an amount of tax mentioned in a pre-filled challan in the form GST PMT-06 for an amount equal to 35% of the tax paid in cash.

12.2 Self-Assessment Method (SAM)

Taxpayers can pay the tax liability by considering the tax liability on inward and outward supplies and the input tax credit available. The taxpayer has to manually arrive at the tax liability for the month and has to pay the same in form GST PMT-06.

纳税人可使用 GSTR-2B 表格来确定当月可用的进项税额（ITC）。在某些情况下，无需缴纳任何税款，例如：

• For the first month of the quarter – where the balance in the electronic cash/credit ledger is adequate for the tax liability of the said month OR where the tax liability is nil.
• For the second month of the quarter – where the balance in the electronic cash/credit ledger is adequate for the cumulative tax liability for the first and second months of the quarter OR where the tax liability is nil.

注意：

• 除非注册人已提交该月之前完整纳税期的申报表，否则不符合上述程序的资格。
• 完整纳税期是指该人员从纳税期第一天到最后一天均处于注册状态的纳税期。

13. 常见问题解答 (FAQ)

13.1 QRMP 计划的选择是否按 GSTIN 进行？

是的，QRMP 计划的选择是按 GSTIN 进行的，一旦选定，即对未来的纳税期有效。因此，纳税人可以为一个 GSTIN 选择 QRMP 计划，而对另一个 GSTIN 继续按常规计划申报。

13.2 如何加入该计划，符合条件的人员可以直接迁移吗？

为享受该计划的优惠，现已明确：凡 2019-20 财年总营业额不超过 500 万卢比，且已在 2020 年 11 月 30 日前提交 2020 年 10 月份 GSTR-3B 表格的注册人员，均可在通用门户网站上自动迁移。

13.3 如何进行按月缴税，缴税截止日期是什么时候？

QRMP 计划下的注册人需在季度前两个月的每个月，通过 GST PMT-06 表格存入应缴金额来缴纳税款，税款应在次月 25 日前缴纳。

13.4 选择按季度申报 GSTR-3B 的注册人的截止日期是什么时候？

选择 QRMP 计划的注册人需在每个季度结束后的 GSTR-3B 表格 申报截止日期（即该季度次月的 22 日或 24 日，视具体情况而定）之前完成申报。

13.5 注册纳税人何时以及如何退出该计划？

退出该计划的申请可在上一季度第二个月的第一天至本季度第一个月的最后一天期间提交。此外，若注册人在本财年某个季度的总营业额超过 500 万卢比，则应从下一季度起改为按月申报。