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GST Network

Presented by
Shashi Bhushan Singh
VP, GSTN
shashi.bhushan@gstn.org.in

Ahmedabad Date:2 /10/2016


Agenda
1. Existing Indirect Tax regime and its Problem
2. Features and benefits of Proposed GST regime
3. Requirement of GST Network
4. IT Strategy
5. Rollout Strategy
6. GST System Architecture
7. Overview of GSP ecosystem
8. GST System Progress and Plan
9. Information and Disaster Management
10. Demo of Registration, Payment and Return
11. Challenges for business
EXISTING INDIRECT TAX STRUCTURE

Entry Tax & Octroi

Customs Excise Entertainment Tax


Duty Duty
Electricity Duty

Central Luxury Tax


Levies
Central VAT
Service
Sales Tax
Tax

State
Levies

29 States, 2 UT with Legislature and


few UTs
Problems in Existing Indirect Tax Regime
• Cascading
– Restriction of credit flow across states and central
jurisdictions
• Narrow and Truncated Tax Bases
• High Compliance Cost
– Different rules and regulations in centre and States
– Hundreds of Return and Annexures
– Weak Information Technology Infrastructure
– High verification cost to tax payers
– Classification disputes of goods/services
– High litigation
• Different tax rates in different States
• High Variation in Tax Rates across goods
Consequences of Existing Indirect Tax Regime
• Economic distortions
• Inefficient Distribution networks with depots in all
states.
• Incentives to have multiple small units in each states
• Relatively High tax rates
• Relatively higher costs and higher prices
• Relatively high Risk perception in foreign countries
• Country Ranked lower on ease of doing business
• Negative impact on foreign investment
• Retarding effect on economic growth
• Sluggish growth in government revenues
• Restricting the state to invest in physical and social
infrastructure and provide social security schemes
Features of Proposed GST
• Destination based Dual GST consumption tax
– the federal nature of constitutional polity
– Most of welfare functions performed by State
Governments
– Full Tax will be borne by the final consumer
– Tax will flow to the States where consumption takes place
• Wide and common tax base for Centre and States,
for the whole value chain
• Harmonised process and procedures
– Appearance of One Indirect Tax for the whole country
– Facilitated by GST Council
– Single GST Common Portal
– With 25 states and UT uniform backend process being
developed by GSTN
Features of Proposed GST
• Seamless flow of credit through the whole value
chain
– Credit of taxes paid on all inputs, Goods or Services
• Seamless flow of credit across the whole country
through IGST and its cross utilisation
• Settlement of IGST and its cross utilisations
• Prompt verification of input tax credits and
prompt refunds
• Separate registration in each State
Benefits of Proposed GST (cntd.)
• Strengthen the Indian Nation as one market
• Neutrality of tax regime to production and distribution
decisions
• Improve ease of doing business and minimise
compliance cost
• Lower tax rates
• Lower Prices
• Attract foreign investment
• Higher economic growth due to low prices and more
investment
• Higher revenues due to boost to economic growth and
better compliance
Role of GST Network
• A common interface for taxpayers for all his GST
compliance needs , GST Common Portal for
– Registration
– Payments
– Returns
– Refunds

• Prompt Verification of IGST Credit, CGST Credit and


SGST Credit
– To minimise problems to bona-fide taxpayers
– To facilitate prompt refunds
– To facilitate Intra-governmental fund settlements
Role of GST Network
• Prompt and error free Settlement of funds between
state and central governments
– Cross utilisation of credits
– devolution of IGST to consumption states

• Developing and Managing the Information technology


infrastructure and Applications for the backend
processes in a cost effective manner to the needy
governments
Goods and Services Tax Network (GSTN): The IT
Backbone of GST
a. 70 to 80 Lakhs taxpayers;
b. 260 to 300 Crores B2B
invoice data per month
c. More than 120,000 tax • Strong IT
Infrastructure
officials to work • Independent
d. Monthly filing of returns • Flexibility of
e. Credit of ITC Pvt Sector
• Strategic
f. Creation of Business Control of
Intelligence reports and Govt
Analytics
g. Both Central and States
Tax Departments
Goods and Services Tax Network (GSTN)
a. Special Purpose Vehicle (SPV) set-up by GOI and all State
Governments for laying the IT Infrastructure for GST, incorporated on
28/03/2013 as Section 25,
b. Exclusive national agency responsible for delivering integrated
Indirect Tax related services involving multiple tax authorities
c. Provide common Registration, Return filing and e-Payment services
to the taxpayers
d. Ensure integration of the GST Common Portal with existing tax
administration systems of Central / State Governments and other
stakeholders
e. To run the clearing-house mechanism for IGST amongst centre
and states
f. Provide Analytics and Business Intelligence to tax authorities
g. Carry out research, study best practices and provide training to the
stakeholders
GSTN’s Structure
1. Goods and Services Tax Network (GSTN) is a Section 25 (not for profit),
non-Government, private limited company. It was incorporated on March
28, 2013.
a) 49% shareholding with Government (24.5 % central government and
24.5% with all states put together)
b) 51% shareholding with private financial institutions where no one
can have more than 11%
2. Jointly controlled by the Central and State governments
3. Technically a private Company to ensure operational flexibility
GST IT Strategy
Harmonization of Business Autonomy of back-end systems of
Processes and Formats States and Centre

Common & Shared Centre/States


IT
IT Infrastructure Tax IT Systems
Interfaces

• Core Services • Approval of Registration


Non-Statutory Functions

– Registration • Assessment

Statutory Functions
– Returns • Refunds
– Payments • Audit and Enforcement
• Helpdesk support • Adjudication
• Information on Inter-State supply and • Internal workflows to support
cross-credit utilization above functions
• Analytics • Recovery
• IGST Settlement • Analytics and BI
GST IT Strategy
State / Centre Tax
Tax Authority Interface GSTN IT Systems Taxpayer
IT Systems
State/Centre Portal GST Common Portal
API
Interface

State / Common API


State/ Centre GST
Centre Portal Interface
Application Application
Database Database

API Network of
Accounting Agencies
Interface Banks & RBI
& Treasuries
GST Rollout Strategy
State/CBEC to develop their own backend modules and exchange
data with GST common portal using APIs over a secured network

1
APIs
Data enter

State 1

GST Common Portal + WAN 19 States/UTs


2 Network
State 2

Backend System State n

API: Application Programming Interface


States and UTs with legislature States
Model-1 and Model-2 States
1 Arunachal Pradesh
2 Assam
1
2
Andhra Pradesh
Goa
List of Model-2 States
3 Bihar 3 ListHaryana
of Model-1 States
4 Delhi 4 Karnataka
5 Himachal Pradesh 5 Kerala
6 Manipur 6 Maharashtra
7 Mizoram 7 Meghalaya
8 Nagaland 8 Sikkim
9 Odisha 9 Tamil Nadu
10 Puducherry
11 Tripura
12 Uttar Pradesh
13 Uttrakhand
14 Madhya Pradesh
15 Chhattisgarh
16 Jharkhand
17 Gujarat
18 Punjab
19 Rajasthan
CBEC
20 West Bengal
21 Telengana
22 J & K
UTs Without Legislature
1 Chandigarh
Key Architecture Principles
• Platform Approach
– SOA based Architecture (all GST System functionalities available as
Services)
– API driven (All services exposed as API)
– APIs available for developer community to build Mobile Apps,
Portals, Custom Application etc.
– Platform open for innovation
• Openness
– Use of open source technologies/Frameworks
– Use of open API standard (restful APIs)
• No Vendor Lock in and Replace-ability
– Usage of proprietary software/framework only if no equivalent
open source framework/component available
– Usage of software/framework through open APIs only
Key Architecture Principles
• Security & Privacy
– Security using Symmetric and Asymmetric cryptography
– Usage of Digital Signature and e-Sign
– Secure Communication with outside world using MPLS/VPN/SSL
– Advance SOC (Security Operation Center) and Security Policy
• Scalability
– Massive scaling using SEDA (Staged Event Driven Architectures), Micro Service
Architecture and Messaging System
– Stateless APIs
– Design for Horizontal Scaling
– Container (Docker) based deployment
– High level of Automation using automated dev ops
• Manageability and Lights-out Operation
• Automation of deployment through dev ops
• Usage of advance monitoring tools to provide proactive alerts
• NOC (Network Monitoring Center) connected with monitoring tools to provide
remote monitoring
Key Architecture Principles
• Reliability
‒ Design for Zero Data Loss
‒ Temper proofing of data using hashes ,encryption and access
control to prevent unauthorized access/modification of data
• Availability
– NO SPOF (Single Point of Failure)
– Every component in HA
– Active Active Data Centre
– Provision of NDC
• Data Driven Decision Making
‒ Usage of Big Data Technologies to handle and process large
amount of data
‒ Usage of BI and Analytics to provide better services to tax payer
Key Architecture Principles
• Reconstruction of Truth
‒ All Signed and Important uploaded data is to be stored in
original in HDFS/Tapes
GST Platform Architecture
Layered Architecture

End Users Interface


Layer

External Stake
Holders Layer

Infrastructure Layer

API Layer

Core API
GST Platform Architecture
GST System consists of five layers

• GST Core System


‒ It is heart of the system
‒ It has all the business logic, business rules implemented
‒ It has implementation for Digital Signature solution
‒ It has implementation for reconstruction of truth, security of data
etc.
• API Layer
‒ It is the interface of GST Core System
‒ This layer abstract and protect GST core System
‒ All security measures like License Key Validation, Authentication ,
Coarse Grained Authorization have been implemented in this layer
‒ All other things related to API like throttling, metering, auditing,
access management have also been implemented in this layer
GST Platform Architecture
• Infrastructure Layer
‒ This layer act as a backbone of system
‒ This layer provide infrastructure support for hosting API’s and other
Application
‒ This layer provide physical as well as virtualized server along with required
deployment infrastructures (Application Server, Webserver, Messaging
Infrastructure, physical as well as virtual Storage Infrastructure etc.) for API
and Application deployment
‒ This layer provide all network and communication infrastructure for GST
System and interface for external stakeholders to connect to GST System
• External Stake Holders Layer
‒ Through this layer only all public API’s will be available to outside world
‒ This will be a layer, which will be hosted mostly by GST partner i.e. GST
Suvidha Provider (GSP)
‒ GSP will be securely connected with GST infrastructure
‒ This layer will allow GST system to provide access to all public APIs to
external stake holders in more controlled and secure way
GST Platform Architecture
• End User Interface Layer
‒ This layer will be the face of GST system for end users (Tax Payer, Tax Consultants, Tax
Officials etc.)
‒ This layer would have applications like Web Portal, Mobile Apps, Mobile based Web
Application etc.
‒ GST system will provide some of these applications like Web Portal both for Mobile
and Desktop.
‒ GSP and their partners using public APIs are also free to provide any of above or any
other application to end users
High Level GST Platform View (Tax Payers)

Tax Payers Tax Payers Tax Payers Tax Payers Tax Payers

Custom
Accountin
Company ERP
g Package
Application
Desktop Browser Mobile Apps

Offline Utility
Prepare
Invoice,
Registrat GSP GSP GSP
ion Data

Tax Payers Desktop / Mobile


Browser

API Gateway
GST
Common
Tax Payers Portal Core GST Engine
Desktop / Mobile
Browser
High Level GST Platform View(Tax Officials & Others)

Sate Government Bank &


Systems (Model 1) CBEC
RBI

API Gateway
GST Back
Office
Tax Official State/
Portal Core GST Engine
Desktop /
Center Mobile
Browser
Key Technological Features

• Use of latest big data technologies to


handle high volume and high velocity
return data
• Use of latest stateless lean restful API
based architecture
• Use of latest multi-layered security
measures
• Use of open source software
• Provision for massive scalability
Solution Architecture
Overview of GSP Ecosystem
• GST System is following a platform approach for providing
services to Tax Payers.
• All GST System functionalities like registration of entities,
uploading of invoices, filing of returns will all be available
through APIs.
• GSTN believes in creating an ecosystem of Service
Providers viz GST Suvidha Provider (GSP) providing
innovative solutions (Portal, Mobile App, Enriched API)
either themselves or through its third party partners for
making tax filing more easy and convenient to tax payers.
• GSTN envisages a very important role of GSPs in making
GST rollout easy and convenient for tax payers.
Overview of GSP Ecosystem
Some of potential stakeholders/prospective GSPs
could be:
• Business groups / industry groups having common
commercial interaction platforms
• Custom Application providers providing platform
services to various trade bodies.
• Accounting Software providing companies like Tally,
Swift, Fact etc.
• ERP Solution providers like SAP, Oracle, Microsoft,
Ramco, Cloud ERP service provider.
• Startup and Small companies providing Accounting
and Billing solution for SMEs and small retails shops.
Functionalities Available for GSP through API

• GST Common Portal has three main Module


‒ Registration of Tax Payer and Tax Consultant
‒ Returns (GSTR1-GSTR12)
‒ Payments
‒ Ledger Maintenance
‒ Miscellenous
Registration

• Registration Module has below major functionalities


available as API:
‒ New Registration
‒ Amendment to existing registration
‒ Cancellation of registration
‒ Opting in/out from composition
‒ Revocation of registration
‒ Surrender of registration
‒ Work flows for handling all above functionalities
Returns
• Return Module has below major functionalities available
as API:
‒ Upload invoices (Various types B2B, B2C etc.)
‒ Update Uploaded invoices
‒ Accept/Reject/Modify counter party invoices
‒ Generation of GSTR1-GSTR12 return based on
uploaded invoices and counter party actions
‒ Amend GSTR1, GSTR2
‒ Auto population of GSTR2, GSTR3, GSTR4 etc.
Payments

• Payment Module has below major functionalities available


as API:
‒ Creation of challan
‒ Payment History
Ledger

• Ledger Module has below major functionalities available


as API:
‒ Utilization of Cash and ITC for tax Payment
‒ Viewing of ITC, Cash and Tax Liability Ledger
Miscellaneous
‒ HSN/SAC code search
‒ Tax payer or Tax Consultant search
‒ Grievance creation
‒ Notification of Alerts and notices
‒ Search for opt in/out composition dealers
‒ Other…
Challenges for Tax payers and opportunities for GSP

• In GST system all Tax payers have to provide details of all


invoices along with all line items in a particular format for
various returns. This mandate will require some sort of
automation at all Tax payers end. Of course already
automated systems have to be tweaked to comply with this
mandate. So it is a big opportunity for GSPs.

• In GST regime buyer’s various returns will be auto populated


based on Seller filling. This bring in additional complexity to
match seller uploaded invoice and accept/reject/modify
these invoices. GST system will not allow duplicate invoice
upload.
Challenges for Tax payers and opportunities for GSP

• Most of the tax payers have to now file three returns in a


month (Amendments are not included).
• Large amount of data to be uploaded in return So
automation will be the need of the hour for tax payers.

• There will be auto reversals etc., so Tax payers have to


keep a tab on different scenarios, without automation it
will be difficult.

• Synchronization between Tax payer system and GST


system will be a challenge. Automation using APIs will
be required to do that.
GST System : Outline of Scope of Work for MSP
Track Scope of Work
I Application design, development and
implementation
II Taxpayer one time Data Porting
III IT Infrastructure procurement, supply,
installation and Info Security
IV DC/DR Hosting Services including providing
Bandwidth for the project
V Helpdesk Setup and Operations
VI Training and Capacity Building
VII Operations and Maintenance of the GST
System for 5 years

MSP: Managed Service Provider.


GST System : Progress and Plan
• Selection of INFOSYS as MSP through open bidding for
development, implementation and operations of GST
system for five years in September 2015
• Finalisation of Business Requirement Description (BRD) for
the core services of Registration, Return, Payment and MIS
Reports in March 2016
• Finalisation of Software Requirement Specification (SRS)
for the core services in June 2016
• 46 initial G2G API to be used by Model 1 States Released
for Mock Implementation and Testing on Sandbox till now
• Prototype development of key use cases completed in
September 2016
• Key G2B APIs in the process of being released for Mock
Implementation and Testing.
GST System : Progress and Plan (Contd.)
• Staggered Releases starting from September till December 2016
• Release 0 - Migration and Registration October 2016 ,
• Release 1:- Registration, Return and Payments , October
2016
• Release 2:- Migration, Registration, Return, Reports
November 2016
• Release 3: Registration, Return, Reports , December 2016
• Testing to get Completed by February 2017
• GST System Software to be available for beta testing in February
2017
• Training of Master Trainers on GST System Software to begin in
January 2017 and completed in February 2017
• Migration to be completed by March 2017 and Provisional
certificate issued on 1st April 2017
Migration
• Planned to Commence in October
• Gigantic exercise as it encompasses
• Generation and distribution of GSTIN to around 65
to 80 lac taxpayers
• Generation and distribution of passwords to these
tax payers
• upload of the details and supporting document by
taxpayers in the GST system
• Planned to be done in a staggered manner with a
few states to be taken up one at a time to manage
load
Auditing and Logging
• All Tax payer transactions will be logged and based on sensitivity (like
return filling, payment etc.) audit trail will be retained.
• Tax Payer Activities on portal will be logged to improve user
experience.
• All login attempts success/failure will be logged for monitoring to
prevent misuse and hacking of accounts.
• All important/sensitive actions of tax officials will be logged like
downloading of Tax payer details, Searching of patterns which are
throwing large result set to prevent misuse of system.
• All access to database will be logged and monitored
• All changes made to system like creation of new user, change in
privileges etc. will be logged and monitored.
• All digitally signed data will be stored for any dispute.
Information Classification
Level Description Examples
Level 1 Information that is available to (i) GST web public content
(Public) all GST system users without (ii) GSTIN, Status, Name
any restrictions
Level 2 Information is available to only (i) Configuration parameters
(Internal) a sub-set of internal users from (ii) Rules
GSTN & SP (iii) Application Logs etc.
Level 3 Level 2 restrictions plus (i) Sensitive data and personal
(Confidential) Information is sensitive needs information (Bank account details,
to be protected through PAN, Aadhar number)
Encryption or through other (ii) Personal information such as
data masking techniques Mobile number, Address, Email id
(iii) Invoice data, Tax returns details,
Ledger entries
Level 4 Information that available to (i) Passwords
(Secret) only very few (1 or 2) users. (ii) Digital signature, Encryption keys
(iii) Highly confidential Govt
communication
Information Security Dimensions
• Confidentiality
– Ensure Data is only visible to intended personal
– Controls: Anonymization, Encryption, RBAC
• Data Protection
– Ensure data can only be modified by people who are
authorized
– Controls: Database Activity Monitoring, Encryption
• Integrity & Non-Repudiation
– System to detect any unauthorized changes to the data
– Controls: Encrypted Checksum, PKI based Digital
Signatures
• Recoverability
– System with ability Reconstruct the Truth
Integrity – Non-repudiation Approach
• PKI based Digital Signature will be mandated for all
Medium - large tax payers
– GST System will mandate PKI based Digital Signature
for all filing of statutory forms (Returns, Refunds,
Registrations etc.)
– Signing using Class-2 or Class-3 Certificate
– Additionally, GST System will also support e-Sign
• Electronic Verification Code (EVC) based approach for
non-repudiation will be allowed for small Tax Payers
(Similar to Income Tax)

PKI: Public Key Infrastructure


Data Centers: Reliability and Availability
• DC and near DC in NCR & DR (DC2) and Near DR
in another Seismic Zone(Bangalore)
• DC and DR (DC2): To work on active – active
Architecture
• To be housed in commercial Tier III Data Centers
• Near site data centers as bunker sites for zero data
loss
• All the IT infra deployed would be dedicated for
GST System
• 24x7 monitoring and management through
dedicated ESM tools and Teams
Application User Interface Preview
based on work in Progress of
prototypes

http://172.18.4.63/proto
Process Overview - Registration
• PAN based common registration
• State-specific registration. Multiple registration in one State also possible in selected
cases
• No physical submission of application
• No pre-registration site visit by Inspectors
• Post site visit by Inspector only in specific cases based on risk parameters
• Time limit prescribed for approval by Registering Authority
• Approval for amendment only if changes are w.r.to Core details : Name of business
entity, Principal place of business, Details of proprietors/partners/karta/MD,
Compounding scheme

• Auto prefill of maximum fields in case of additional registration or


any other registration
• Approval from Central & State Registering Authority required
• Central or State Authorities have power to cancel registration
• Submission of Form through TRPs and FCs as well as offline utility
• Status tracking
• Auto migration of existing taxpayers to the GST system 50
Application Preview - Registration
• Following Video shows glimpses of new GST
Portal for Registration Module
• The video covers Registration by New Tax
Payer

Verification
•Place
Provide Details •Authorized
signatory
•Business Details •Date
•Principal Place of •DSC/ E-Signature/
Business EVC
Validation •Promoter / Partner
•Email OTP etc
•Mobile OTP •Goods and Services
•Bank Accounts
•Authorized Signatory
•Additional Place of
Enter Basic Business
Information •State Specific
•PAN Information
•Email ID
•Mobile Number
51
Process Overview - Payments
• Single challan for CGST, SGST, IGST and Additional Tax. All payments can be done
through one challan
• Challan to include all major heads (IGST, CGST, SGST, Additional Tax) and minor
heads (Tax, Interest, Penalty, Fine, Others)
• Payment through Debit/Credit Card, Internet Banking, NEFT/RTGS and at the Bank
Counter
• Facility to make advance payments
• All payments will become part of Cash Ledger and can be utilized in payment of
liabilities
• Maximum Time limit prescribed for making payment if challan generated

• Prefilled Challan except for amounts


• Facility to make payments under different major/minor heads within one
challan
• Refund can be claimed for excess payments
• Facility to track payment
• Facility to link UTR in case of NEFT/RTGS
• Facility to generate challan with pay later option is also available
52
• Payment can be made through un-associated banks also via NEFT and RTGS
Application Preview - Payments

• Following Video shows glimpses of new GST


Portal for Payments Module
• The video covers creation of Challan for
various payments. It covers

Entering View
Selection
various tax Generating Making Receipt,
of Payment
liability Challan Payment Print and
Modes
details Download

53
Process Overview - Returns
• Uploading of only outward supplies.
• Invoice-wise, HSN/SAC Code wise filing of outward supplies
• Facility for Buyer to add invoices missed by supplier for claiming
Input tax credit
• Validation on GSTIN of Buyers and Sellers and Validation of the
Import/Export data from CBEC & DGFT systems.
• Uploading of invoice details in phased manner
• Auto generation of purchase details based on Outward supply returns
filed by vendor
• Facility to file corrections in subsequent returns till filing or due date of
filing Annual Return for the year
• Auto creation of Monthly Return based on Invoice details uploaded
through GSTR-1 or GSTR-2
• Facility to file returns through TRPs and FCs
• Facility to file using offline utility and GSPs. For any mistake error
message will be displayed.
• Tax Ledgers (Liability, ITC and Cash) available for summarized and
detailed view
54
Returns Forms Overview
5
5

5. B2B 4. B2B 5. Turnover 4.B2B 4. TDS


6. B2C Large 5. Import 6. Outward Details
Supplies 5.ISD
7. B2C Small Goods 5. Other
8. Credit/Debit 6. Import 7. Inward Distribut Amount
Supplies ion
Note Services Paid
8. Total
9. Amendment 7. Credit/Debit Liability 6.ISD
s Note 9. TDS Credit Ledger
10.Nil Rated 8. Amendments 10.ITC Credit
11.Exports 9. Nil Rated 11.Tax Paid
12.AT Liability 10.ISD Credit 12.Refund
13.AT Paid 11.TDS Credit Claim
12.Partial
Credit

GSTR-1 GSTR-2 GSTR-3 GSTR-6 GSTR-7


(Outward (Inward (Monthly (ISD (TDS Details)
Supplies) Supplies) Returns) Distribution)
Filing of Monthly Returns by Taxpayer

Taxpayer 2

GSTR-1
Taxpayer 1 (Return of
(Missed Outward
GSTR-1 Invoice Supplies)
(Return of Added)
Outward GSTR-3(Monthly
Supplies) Return)

The details filed


GSTR-2
(Return of via GSTR-1 and
Inward GSTR-2 will be
Supplies) auto-populated
in GSTR-3
Application Preview - Returns
• Following Video shows glimpses of new GST
Portal for Returns Module
• The video covers Outward Supplies Return –
Form GSTR1. It covers

Invoice data
Upload Section View Summary of View Invoice data uploaded by Tax
Wise details uploaded data summary Payer (View /
Update / Delete)

Invoices filed by Invoices uploaded Invoices filed by


Filing GSTR1 by
Receiver in GSTR2 by Receiver and supplier but
affixing DSC/ E-
(Pending / Accept Modified by Tax Modified by
Signature/ EVC
/ Reject) Payer Receiver

57
Challenges for Business
• Need to identify
– the taxable events
– Place of supply
– Time of supply
– Taxable value
– States of registration
• Migration of existing registration and identification of new
registration
• Customization of the software to generate return for each
GSTIN
• One time cost
– Updating the IT applications
– Consultants
– Cash flow for payment of tax on taxable transactions without
consideration

58
Questions and Answers
Thank You

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