Goods and Services Tax Council recommends B2B e-invoicing extension with B2C pilot and voluntary option
The GST Council, which overseas the operations of India’s GST regime, on 9 September 2024 at its 54th meeting said that it is now recommending a voluntary pilot for B2C transactions, followed by mandating for all if successful. The pilot will be rolled out on in selected Sectors and States. An intermediate step would be voluntary.
India introduced mandatory B2B e-invoicing in a phased rollout from October 2020. The current annual sales threshold for the mandate is ₹5 per annum (INR 50 million or approximately US$600,000) – last lowered in August 2023. This includes a requirement to first submit invoices to the offical Invoice Registration Portal (IRP) for validation and allocation of a unique code. Only then may it be forwarded to customers.
The launch date is likely to be 2026 or 2027.
Jan 2024 E-way with e-invoice checks on hold
Goods movements within India will eventually require an e-way electronic reporting and e-invoice details on B2B and export transactions. The aim of the National Informatics Centre, which operates the e-way portal, is to reduce the opportunity for Goods & Services Tax fraud by reducing differences between the two reporting regimes.
Mandatory e-invoicing, with live governmental reporting, was first introduced in India in October 2020. The threshold for reporting has gradually been reduced, and now stands at ₹5 per annum since 1 August 2023.
An E-way is an Electronic Way bill for movement of goods. It includes information such as the name of consignor, consignee, transporter, the point of origin of the movement of goods and its destination. A GST registered business cannot transport goods in a vehicle whose value exceeds Rs. 50,000 without an e-way bill which is generated by registering a movement of goods on the government’s E Way Bill portal.
B2C-related goods movements will not require e-invoice details on the e-way bill.
Separately, taxpayers with an annual aggregate turnover exceeding Rs 5 crore will be required to provide at least a 6-digit Harmonized System of Nomenclature (HSN) code, while those with less than Rs 5 crore need to provide at least a 4-digit HSN code.
Nov 2023: GST Network imposes 30-day e-invoice upload deadline 1st Nov 2023
The GSTN has imposed a 30-day e-invoice uploads deadline to the Invoice Registration Portal (IRP).
This new deadline has been moved several times, and was originally intended to be a 7-day deadline.
The 30-day countdown starts from the transaction and not date of receipt. Initially, this will only apply to taxpayers with a turnover of Rs 100 crore and above. This will apply to credit or debit notes.
Presently, taxpayers can include e-invoicing at current date and there is limited legal definition of timescale.
April 2023 – Option for voluntary GSTN e-invoicing opens
The GSTN has opened its national e-invoicing registration portal (IRP) to all taxpayers to use for creating and sending electronic invoices to customers. Presently, only taxpayers with ₹10 or above sales revenue per annum are mandated to use the governments e-invoicing system.
Under GST law, businesses cannot avail input tax credit (ITC) if invoices are not uploaded on the IRP.
Nov 2022 – New Frequently Asked Questions for e-invoicing and e-waybills
The Indian e-invoicing FAQ’s have been updated this month. Topics covered include:
- e-invoicing processing with supplier processes
- e-waybill creation deadlines
- e-waybills for train transport
- calculating year-end turnover thresholds
- creating e-waybills with e-invoices
- reporting and submissions of e-invoices
Indian B2C e-invoices
For B2C invoices, a QR Code must be included in any invoice by a mandated supplier. Indian e-invoicing is administered by the Central Board of Indirect Taxes & Customs (CBIC), which also oversees the operations of India’s Goods and Services Tax.
India introduced e-way bills in April 2018 as digital notifications of goods movements. Check VAT Calc’s global live VAT invoice transaction and e-invoice reporting tracker to see where else real-time submissions of invoices is being implemented.
Invoice Registration Portal IRP for e-invoices clearance
The steps to issue an Indian e-invoice are as follows:
- Any draft e-invoice must firstly be transmitted to the Invoice Registration Portal (IRP), which may be done by an Application Programming Interface (API) through a JSON file.
- The IRP performs basic validation checks on the invoice:
- Complete invoice details
- Checks supplier’s and custom’s GST identification numbers (GSTIN)
- Checks invoice number and date; and
- Verifies not a duplicate invoice
- The IRP then issues:
- a unique Invoice Reference Number (IRN);
- a unique Quick Response code (QR Code). This is a square matrix bar code which provides a URL address for electronic readers to access information at the IRP about the invoice. The QR code is used by any party to check the invoice entry in the IRP.; and
- an IRN e-signature.
- The invoice and QR code are then shared with the customer by the invoice supplier. The customer must agree to the details. The supplier and customer must agree on the format to share the invoice as it is not currently available within the IRP. Typically, it is done by PDF or paper copy invoices.
- The invoice and QR code are also send to the GSTN and the National Informatics Centre (NIC) to ensure all data is reconciled.
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