Issue & Solution with J1INEMIS Reporting due to Statutory Changes
Central Board of Direct Taxes (CBDT) – Ministry of Finance – Government of India has released a circular dated 13.05.2020 of reduction in TDS & TCS rates for to provide more funds at the disposal of the taxpayers to deal with the economic situation arising out of COVID-19 pandemic, the rates of Tax Deduction at Source (TDS) for the non-salaried specified payments made to residents has been reduced by 25% for the period from 14th May, 2020 to 31st March, 2021.
For tax rates break-up and further inputs , please refer below circular link:-
Reduction in TDS-CBDT India Circular
Purpose of this blog :-
To understand the challenges arises in J1INEMIS reporting by adopting formula based TDS method along with the best possible solution to overcome those challenges.
Solution by SAP for TDS rate reduction:-
SAP released a note describing solution to achieve this statutory requirement of TDS rate reduction due to COVID-19 w.e.f.14-05-2020 in SAP system for an India Enterprises.
Challenge in TDS reporting with SAP note – 2925854 :-
SAP note “2925854” advised to go for a formula based configuration & to split existing TDS tax code into date validity from 14.05.2020 (reduced TDS rate) & after 01.04.2021(Full TDS rate) , doing so the TDS calculation did happens correctly in all vendor invoice/advance transactions however TDS rates are not getting updated in SAP standard TDS report J1INEMIS or its source table WITH_ITEM.
SAP released new Note – 2930256:-
We raised an OSS to SAP asking guidance on TDS reporting problem, SAP responded to our query with a new SAP note which states that when formula based method is used WITH_ITEM table is not updated with tax rate & report J1INEMIS ,also for country India localization, formula base method for withholding tax calculation is not supported.
Furthermore,SAP has suggested to roll back to tax rate based configuration as it was earlier.
Practical Solution to address this requirement:-
Now, the statutory relaxation of reduction in TDS rate applicable from 14.05.2020 till 31.03.2021 remains the same and switching back to old method of tax rate at TDS tax code level & not formula based will requires a change of configuration post 01.04.2021.
This change in configuration after 01.04.2021 can lead to inconsistencies in all TDS invoices/ down payment open items & it may create issues with year end closing also.
So, let us just look at what could be the best feasible solution that should be adopted to avoid such manual intervention, inconsistencies & reporting issues.
Step-1:- Create new TDS tax type for reduced rate
Step-2:- Create TDS tax code for newly created TDS tax type for reduced rate
Step-3:- Assign newly created TDS tax types to company code
This step is a crucial one , here change the validity of existing full rate TDS tax type & provide validity to the newly created TDS tax type for as per legal notification.
Reduced rate TDS tax type
Full rate TDS tax type
Step-4:- Assign TDS GL to newly created reduced TDS tax type
Master Data Management :-
Vendor Master Withholding/TDS data must be maintained with newly TDS reduced rate, let the old TDS tax type for invoice & payment remain intact.
Transaction Testing :-
Vendor Invoice document posted with posting date 14.05.2020
Vendor Invoice document posted with posting date 01.04.2021
Report Testing :-
Now the TDS standard report J1INEMIS will reflect Withholding/TDS rate along with other information.
Entry in table WITH_ITEM
1- By following above stated process , one can completely eliminate manual intervention,consistencies with respect to TDS transactions & reporting for India Localization.
2- It is to be noted that Withholding/TDS tax type’s for reduced percentage should be created for all existing TDS type with its tax code/percentage combination for invoice as well as payment & this should be maintained in required vendor master , so essentially every vendor master will have minimum 4 tax type assigned to it i.e. 2 for invoice & payment of reduced rate & 2 for invoice & payment of full rate.
2- Run Report “RFWT0010” in SE38 after making any changes in TDS configuration to avoid consistencies in clearing.