GST rates for restaurants has been a hot topic over the last few months.
The government is of the opinion that restaurants have not passed on GST
benefits to customers and have used GST to increase their profits. From the government's perspective they are correct. Restaurants (those who were earlier in
the composite model - 80%+ of the industry I guess) have used GST as a way
to charge customers more and have conveniently blamed the government for it.
The alternate view on this is that most restaurants were waiting for GST before
revising prices (which most restaurants do annually by about 5-10%) and have
simply held off on raising prices because of the GST rollout. Thus in some ways
by not increasing prices, the benefits have been passed on to the customers. In
my opinion the real issue that irked the government was the fact that the
restaurant industry by and large communicated to customers that the price
increase is because of GST and they could do nothing about it.
But the government's reaction to the situation is not something I agree
with. Rolling back input credits is a reactionary populist move and is a big
backward step, especially for this already cash heavy industry. By removing
input credits, the government has shown immaturity and a poor understanding of
the ground realities in the industry. The decision has been made without
assessing the long-term implications. Or maybe the government wants things to
function as before thus allowing a cash economy to thrive. Restaurants won’t
complain, suppliers won’t complain, landlords won’t complain and now the
consumers will also applaud the government that they have lowered costs for
them (though they will actually be paying 5% more now than the pre-GST
era).
The decision creates a bigger problem in my opinion allowing the
industry to once again gravitate towards cash collections and payments.
Restaurants can show lesser sales and pay lower GST, pay off suppliers and
landlords in cash without bills thus lowering costs. Landlords and suppliers
are happy to do this as they don’t need to pay GST or can pay lower GST. This
also lowers their income tax pay-outs as they can show lesser income now. Landlords,
suppliers and restaurateurs can play with cash again like before - Their good
days are back. The government has in some ways just given them a 5% bonus to
play with.
The GST rollout was a great opportunity for the government to push the
fragmented restaurant industry and the supporting eco-system to move away from
cash transactions, become more professional, tax compliant and gravitate
towards digital payments.
To put this in context it is important to understand the key taxation
related issue in the restaurant industry and the supporting eco-system:
Lower Sales Reporting by restaurants (by conveniently siphoning off cash
collections), thus resulting in lower GST and lower income taxes payable to the
government.
There are 4 big motivations for the restaurant industry to siphon off
cash collections from sales:
1) Lower input costs: Suppliers are more than happy to offer products
for cash (with no tax). For small suppliers, cash is a more convenient way of
doing business and they don't need to bother about tax filings. It is also a
way for them to compete better with larger/professional suppliers, who charge
taxes.
2) Rental Payments: The biggest incentive to deal in cash is for
landlords and they are very happy to take a large portion of their rental payments
in cash. Cash payments are also a great way for them to reduce income taxes.
They can also ask the restaurateurs to shell out more rent in lieu of the GST
not charged to them (e.g. 18% GST gain split between the landlord and the
restaurateur).
3) Staff Salaries: If restaurants officially employ more than 10 people,
they need to register for ESI and when the number crosses 20, PF becomes
mandatory. They also need to pay annual statutory bonus, leave wages and double
salary for working on holidays (NFH - National Festivals & Holidays). Both
ESI & PF, involve deductions from employee salaries and all of the above
implies higher costs for the restaurateur. The largely migrant restaurant staff
population does not value long term benefits nor are they keen on going to a
ESI hospital. What matters to them largely is cash in hand. Having cash
available to do this means restaurateurs can pay their staff more and avoid PF/ESI
registration & the related expenses and compliance
requirements.
4) Paying lower GST and income taxes - Direct benefit of reporting lower
sales. I believe this is not a primary motivator for restaurateurs and is
simply an added benefit that comes with the solution to address the above 3
issues.
Issue number 3 above (Staff salaries) is not something GST could have
directly addressed. But GST could have truly helped with issue 1, 2 &
indirectly 4.
Allowing input credits may not altogether solve the problem of lower sales
reporting by restaurants, but would have atleast pushed them to ask for proper
bills from landlords and suppliers in order to avail input credit, thus
addressing issue 1 & 2 above. Rental collections by landlords through
banking channels would have a significant positive impact on GST collections as
well as on income tax collections. Smaller suppliers would also slowly
gravitate towards digital payments and proper tax payments. Because of the
above, the restaurateur’s motivation to siphon off cash would reduce and this
will mean higher GST and income tax collections for the government.
The government should have stayed with the GST framework, kept the GST
rate at 12% for all restaurants (or stayed the course with 18%/12% rates as earlier) and allowed them to avail input credit. This
would have ensured better collections and also helped clean up the supporting
eco-system. Businesses would have been encouraged to move away from cash
payments and gravitate more towards digital payments, deal with vendors who are
professional and pay taxes honestly and also force landlords to show the real
rentals they charge, pay GST & income taxes as per the rules. The GST
regime with input tax credits would have slowly pushed the industry and the
supporting eco-system towards becoming professional and paying taxes honestly. This
would not have been a populist move though, but the long-term benefits would
have been very impactful. As for consumers paying more, the government should
have let market forces play their part. Why is the government trying to
regulate whether a customer should pay Rs. 20.50 or Rs.22.40 for an Idly? Food
is an essential need, eating out is not.
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