Understanding Unique Identity Number (UIN) Compliance and Reporting in the GST Framework

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Published Date:  08-12-2023   Updated on:  28-12-2323    Author:   aishwarya-s
understanding uin compliance and reporting in the gst framework

Under the ambit of the Goods and Services Tax (GST) in India, the Unique Identity Number (UIN) serves as a distinctive identifier. Allocated to specific entities, such as foreign diplomatic missions, embassies, and entities exempt from GST, the 15-digit alphanumeric UIN plays a crucial role. This article delves into the comprehensive compliance obligations, reporting requirements, and various facets associated with the UIN under the GST regime.

UIN Registration Compliance Obligations for Organizations

The process of obtaining a Unique Identity Number (UIN) under the Goods and Services Tax (GST) framework in India demands adherence to a set of compliance obligations. This section will provide a comprehensive understanding of the various steps and requirements in the UIN registration process for eligible organizations.

Eligibility Criteria

Organizations eligible for a UIN are typically entities that do not engage in taxable outward supplies. The categories eligible for UIN include:

  • Specialized agencies of the United Nations Organization.
  • Multilateral Financial Institutions and Organizations notified under the United Nations (Privileges and Immunities) Act, 1947.
  • Consulates or Embassies of foreign countries.
  • Any other person or class of persons as notified by the Commissioner.

The process of registration is detailed below.

– Application Submission – Form GST REG-13

The initiation of the UIN registration process involves the submission of Form GST REG-13. This form serves as the official application through which entities declare their eligibility for a UIN. The applicant is required to furnish comprehensive details about its legal entity, principal place of business, and other relevant particulars.

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form gst reg part

form gst reg part
Form GST Reg 13

– Verification and Processing

Upon the submission of Form GST REG-13, the GST authorities undertake a thorough verification process. This verification ensures the accuracy and legitimacy of the information provided by the applicant. The verification process aims to confirm that the applicant falls within the specified categories eligible for UIN.

– Granting or Rejection of UIN

Post verification, the authorities make a determination regarding the grant or rejection of the UIN. The decision is communicated to the applicant within a stipulated time frame. If the application is approved, the UIN is issued in the form of a certificate of registration (GST REG-06).

– Deemed Approval and Timelines

The registration or Unique Identity Number is deemed to have been granted if no deficiencies are communicated to the applicant within the prescribed period. The certificate of registration is issued typically within 3 working days from the date of the submission of the application.

– Prescribed Form and Period for Registration

The registration or UIN is granted or rejected based on the prescribed form and within the period specified by the GST authorities. The application is processed in a manner that ensures timely communication of the outcome to the applicant.

– Communication of Deficiencies

In case deficiencies are identified during the verification process, the applicant is promptly informed. The applicant is given an opportunity to rectify the deficiencies within a specified period. This ensures a fair and transparent process, preventing undue rejections without providing an opportunity for correction.

– Suo-Moto Registration

In addition to applying for UIN using FORM REG-13 on the GST Common Portal, consulates and embassies have the provision for suo-moto registration by a proper officer. This facilitates a proactive approach in ensuring that eligible entities are registered appropriately.

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– Issuance of Certificate of Registration – GST REG-06

Upon successful verification and approval, a certificate of registration in the form GST REG-06 is issued to the applicant. This certificate officially confirms the grant of UIN and provides details about the registered entity.

– Deemed Registration under State/Union Territory Acts

A UIN under the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act is deemed to be a grant of registration or the Unique Identity Number under the Central Goods and Services Tax Act. This is subject to the condition that the application for registration or the UIN has not been rejected under the CGST Act.

Once an entity or organization is registered with a UIN, they must file for returns using Form GSTR 11. More information on this will be provided as you read further.

Mandatory Reporting Requirements for UIN Holders

As entities with a Unique Identity Number (UIN) under the Goods and Services Tax (GST) regime, UIN holders are subject to specific reporting requirements. Unlike regular taxpayers, UIN holders are not classified as “registered persons” under the Central Goods and Services Tax (CGST) Act. This distinct classification implies a certain level of flexibility in their reporting obligations, tailored to the unique nature of their exempted status.

Although exempted from certain reporting norms applicable to registered persons, UIN holders are obligated to maintain specific records. These could include a true and correct account of:

  • Inward supply of goods or services
  • Stock of goods
  • Input/Output tax credit availed
  • Other particulars as prescribed

In the event of any changes in the information furnished at the time of registration or subsequently, UIN holders are required to inform the proper officer. The officer may approve or reject amendments in the registration particulars. The approval process involves considerations based on the information furnished and ascertained by the officer. However, certain prescribed particulars may be amended without the explicit approval of the proper officer.

GST Return Filing and Tax Payment Obligations

UIN holders have distinct obligations regarding GST return filing and tax payment. Form GSTR-11 must be filed by the 28th day of the following month to claim a refund of taxes paid on inward supplies. This form comprises auto-populated information, updated by the supplier, and the UIN holder cannot add or modify any details. GSTR-11 is divided into four sections:

  • UIN: This section requires the input of the unique identification number assigned to notified bodies.
  • Name of the person having UIN: This information is auto-populated at the time of filing the return.
  • Details of inward supplies received: This section necessitates the provision of GSTIN numbers of suppliers, with details auto-populated from the GSTR-1 return form. UIN holders cannot add or modify details in this section.
  • Refund amount: The system auto-calculates the refund amount, with the UIN holder required to provide bank details for refund crediting.

The taxpayer must digitally sign the return through a digital signature certificate or Aadhaar-based signature verification.

It’s imperative to note that UIN holders must file returns within six months from the last day of the quarter in which the supply was received. Failure to claim a refund within this timeframe results in refund forfeiture. In certain cases, an obligation to furnish an information return arises. Any person to whom a Unique Identity Number has been granted, responsible for maintaining records or statements of accounts, must furnish such information within the prescribed time, form, and manner.

E-Waybill Generation and Filing Procedures

UIN holders engaged in the movement of goods must also diligently comply with e-waybill generation and filing procedures. The common portal for e-waybill generation is  https://ewaybillgst.gov.in. Proper registration and authentication enable UIN holders to generate e-waybills. The process involves entering the UIN, receiving an OTP on the registered mobile number, and authenticating the same to generate a username and password for the e-waybill system.

How to Register for e-Way Bill

Recordkeeping and Documentation Requirements

For entities bestowed with a Unique Identity Number (UIN) under India’s Goods and Services Tax (GST) framework, meticulous recordkeeping and documentation are indispensable components of compliance.

Preservation of Invoices: UIN holders are mandated to maintain a systematic record of invoices related to their transactions. These invoices are critical evidence of the goods or services received, helping substantiate the nature and authenticity of transactions. Properly preserved invoices are crucial during audits and inquiries.

  • Receipts and Transaction Documents: In addition to invoices, UIN holders must diligently preserve receipts and other relevant transaction documents. This includes documentation related to the receipt of goods or services, payment receipts, and any other records that validate the transactions conducted under the purview of the UIN.
  • Facilitating Audits and Assessments: The meticulous recordkeeping by UIN holders is not merely a compliance formality; it serves as a foundation for facilitating audits and assessments. Well-documented records enable auditors to efficiently review transactions, verify compliance, and ascertain the accuracy of financial declarations.
  • Ensuring Accountability and Transparency: Beyond the immediate regulatory requirements, robust recordkeeping by UIN holders fosters accountability and transparency in their operations. It demonstrates a commitment to ethical practices and enhances the entity’s credibility.

Navigating UIN Compliance Complexities

Given the intricacies of UIN compliance, a proactive approach is indispensable. Businesses dealing with UIN holders should stay abreast of regulatory changes, seek professional advice when needed, and implement robust internal controls. A strategic and informed approach is vital for ensuring continuous compliance in the dynamic GST landscape. Navigating UIN compliance complexities requires a commitment to monitoring, evaluating, and adapting to changing regulatory requirements.

Understanding Unique Identification Number (UIN) Registration Requirements

Endnotes

UIN compliance is a nuanced and multifaceted aspect of GST in India, requiring a thorough understanding of registration processes, filing obligations, and reporting procedures. Organizations involved with UIN holders must stay informed, adopt proactive measures, and continually assess and adapt to evolving regulatory landscapes. A strategic and informed approach is indispensable for ensuring seamless and compliant operations within the dynamic GST framework.

FAQs

Here are some frequently asked questions.

1. What is the difference between GSTIN and UIN?

Goods and Services Tax Identification Number (GSTIN) is assigned to regular taxpayers who engage in the collection of GST and the filing of corresponding GST returns. It serves as a unique identifier for businesses involved in taxable transactions within the GST framework. On the other hand, the Unique Identity Number (UIN) is exclusively designated for specific entities, such as diplomatic missions, consulates, and other organizations meeting specified criteria. Unlike GSTIN, UIN is not meant for regular business entities but rather for those exempt from certain tax obligations.

2. What is an e-way bill?

An e-way bill is a crucial document mandated by the Government for the movement of goods valued at more than fifty thousand rupees. Governed by Section 68 of the Goods and Services Tax Act and Rule 138 of the associated rules, the e-way bill is generated through the GST Common Portal. It is the responsibility of registered persons or transporters overseeing the transportation of goods to generate the e-way bill before the commencement of the movement of the consignment. This document ensures regulatory compliance and facilitates the seamless flow of goods across different jurisdictions.

3. What is the seller’s protocol for handling UIN clients?

For sellers registered under GST who are supplying goods or services to entities holding a UIN, there are specific protocols to be observed:

  • The UIN must be explicitly mentioned on the invoices issued for transactions involving UIN holders.
  • Such sales are treated as supplies to another registered person (B2B), acknowledging the unique nature of the UIN holders’ tax-exempt status.
  • Invoices for transactions with UIN holders should be uploaded using the same process as regular B2B sales, adhering to GST filing standards.

4. Can UIN holders modify information under GSTR-11?

Notably, UIN holders cannot manually add or modify any information in GSTR-11, as the data is automatically populated from their GSTR-1 submissions. This streamlines the return filing process, ensuring accuracy and consistency. UIN holders, seeking to claim refunds on taxes paid for their inward supplies, are required to file GSTR-11 by the 28th of the subsequent month. This return includes details of taxable products or services received.

5. Can consulates and embassies be granted suo-moto registration?

Yes, after the registration is complete, consulates and embassies can be granted suo-moto registration by a proper officer.

6. What happens if a UIN holder fails to claim a refund within the specified timeline?

If a UIN holder fails to claim a refund within six months from the last day of the quarter in which the supply was received, the refund shall lapse and cannot be claimed.

7. Is UIN applicable only to foreign diplomatic missions and consulates?

While UIN is commonly associated with foreign diplomatic missions and consulates, it can also be assigned to other entities meeting specific criteria, as notified by the Commissioner.

8. Can UIN holders make amendments to their registration particulars without proper officer approval?

A UIN holder should promptly inform the proper officer of any registration details changes as and when they occur. The frequency may depend on the nature and extent of changes. Certain prescribed particulars may be amended without the explicit approval of the proper officer. However, approval is required for other amendments, and the proper officer typically does not reject the application without providing an opportunity for a hearing.

9. Can a regular taxpayer claim input tax credit for supplies made to UIN holders?

A regular taxpayer can claim The input tax credit for supplies made to UIN holders. However, the documentation and reporting process may differ from regular B2B transactions.

10. Is there a specific format for maintaining records by UIN holders?

While UIN holders are required to maintain specific records, the exact format may not be explicitly prescribed. However, compliance is crucial for adherence to the prescribed particulars and maintaining accurate records.

 

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Aishwarya Lakshmi
Aishwarya Lakshmi is a Finance and SaaS Copywriter for 5+ years now, she has created SEO copies for B2B and B2C companies all around the globe. Aishwarya is a finance graduate and a university rank holder with exceptional academic excellence in finance core. Besides writing, Aishwarya, fosters her community Quillspire - a space for budding freelancers. In short, She maps contents to win pitches with words and concepts.

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