The volume of change in GST is the practical difficulty for most businesses. Notifications, circulars, portal advisories, return format changes and judicial decisions all arrive continuously, and most of them do not require any action.
What is needed is a method for separating the few that matter.
The sources worth tracking
Source | What it changes | Typical response time |
|---|---|---|
Notification | Rates, exemptions, rules, due dates and thresholds | Immediate, since it has the force of law |
Circular | The departmental view on an existing provision | Review within the month |
Portal advisory | System behaviour, validations and filing procedure | Before the next filing |
Council recommendation | Direction of a forthcoming change | Plan, but act only on the notification |
Judgment | The interpretation of a provision | Review against positions taken |
A triage method
For each change, three questions decide whether anything needs to be done.
Does it affect a transaction we actually undertake? Most changes will not.
Does it affect a position we have already taken for an earlier period, creating a past exposure as well as a future change?
Does it require a system or master data change, such as a rate change, a new field on an invoice, or a change in reporting?
A change that touches none of the three can be recorded and set aside. A change that touches the third needs the longest lead time, because system changes take longer than policy decisions.
Areas of continuing change
E-invoicing thresholds, which have moved progressively downward and now cover a wide range of businesses
Return formats and validations, where fields become non editable or auto populated over time
Credit restrictions and reporting, particularly the treatment of reversal and re-availment
Rate rationalisation in specific sectors
Appellate mechanism, as the tribunal becomes fully operational
Building the internal process
Assign one person the responsibility of reviewing changes each week.
Maintain a single change log with the source, the date, the effect and the action taken.
Route anything with a system impact to the technology team with a clear implementation date.
Review the log quarterly against the positions taken in the returns.