GST: A Comparative Study of India and Singapore
“Goods and Service Tax (GST) is one of the most pivotal tax reforms for any of the tax ambitious country. Goods and Services Tax is a new-fangled landing of VAT, wherein a widespread set-off for the input tax is being granted. GST have subsumed many indirect taxes from national and state level, in order to amalgamate economy into seamless national marketplace. It is expected that GST would iron out all the wrinkles of earlier indirect taxation schema. This study is an attempt to understand the enactment of GST Laws, with special reference to GST Law of Singapore, so that the experience of Singapore can be usefulimplementation challenges in India.”
Introduction and History
GST is a single tax on the transactions of both goods and services, covering all from manufacturers to the consumers. Herein GST business gets credits of all the input taxes paid at each stage and thus net taxes are payable on only the value addition made by the business house. The final burden of all the taxes are ultimately transferred by the last dealer in supply chain to the consumer who consumes the goods and services.
This concept was firstly introduced by France in year 1954. The success of GST has been such a great success, that it has got replicated in almost as many as 160 countries across the globe. Most of the countries followed unified GST while some countries like Brazil, Canada follow a dual GST system where tax is imposed by central and state both.
In India GST is one of the greatest commercial reform in indirect taxation system, which has made itself one unified common marketplace. Idea of GST was mooted by Vajpayee Government in 2000, but it took long 17 years for India and its legislature procedure to implement the current GST with effect from 1st of July 2017. There are innumerable expectations from the GST, that it shall rollout all the shortcomings of the earlier indirect taxes structure and shall built up India as a strong nation in the world, and it shall be an important catalyst in achieving a benchmark of $ 5 Trillion Economy.
Singapore was among first few of the countries to implement GST in Asian Continent, GST was implemented in Singapore on 1 April 1994 with a minimal flat rate of taxation i.e. 3%, which was roused from time to time and current rate of GST of the country is 7%, the rate of GST in Singapore is lowest in the world since the date on which the same was implemented, and even till date the rate of GST is lowest.
Review of Literature
(SAG Infotech, 2019) In an online publication through their blog page in an article titled “Difference Explained: GST India vs GST in Other Countries” have stated that Singapore follows a single and consistent system of GST rate on every transaction. With its introduction in 1994 the rate was 3%, which has been raised to 7% in 2007, which is a lowest rate as on date in the global market. Across the globe rates of GST are prefixed between 16 to 20 percent and India has somehow taken the cues from this and jotted down the similar pattern.
(Kumar, Revankar, & Jaju, 2018) In an article titled “GST: A Comparative study of India vis a vis Singapore” they compared 5 industries of the two country and highlighted that there is an average difference in prices of the items of 8.91%.
(Gupta S., 2017) In an article titled “Goods and Services Tax (GST): A Comparative Study of Select ASEAN Countries” she stated that by subsuming majority of indirect taxes and cesses levied at the central and state government levels it has simplified the indirect tax regime in India and has put an end to the complex and cascading nature of the multiple tier indirect taxation. GST with implementation in more than 160 countries carries rich history of successes and failures. India should learn from the pitfalls in administration and application of law in developing countries as well as from the successful administrative strategies of the developed countries like Singapore.
(Pathan, 2017) In an article titled “A Comparative Study of GST in India and Other Countries” he stated that the GST has created a lot of buzz since its inception and has been discussed all over India by all the professionals. The impact of GST has been such that each and every one all over the country, whether concerned with it or not has been trying to breakdown the said term. GST in India is implemented with the propaganda of “One Nation One Tax”. It would not be exaggerated to mention over here that the concept of GST is not new to the world as nearly 160 countries as on 2016. He also mentioned that the HST is applicable in Canada, it is good to know that the Indian GST model is similar to the Canadian model of “Duel GST”. Harmonized Sales Tax was implemented by several provinces in Canada to build a more efficient tax system that would improve the competitiveness of businesses in the participating provinces. The HST is a combination of the Canadian GST and Provincial Sales Tax.
(Gupta, Sarita, Singh, Komal, & Kumawat, 2017) In their article titled as “Good and Service Tax: An International Comparative Analysis” stated that the consumption and productions of the goods and services is undoubtedly increasing and because of the multiplicity of taxes in current tax regime, administration complexities and compliance cost is also accelerating. Thus, a simplify, user -friendly and transparent tax system is required which can be fulfilled by implementation of GST. Its implementation stands for a coherent tax system which will colligate most of the current indirect taxes and in long term it will lead to higher output, more employment opportunities and flourish GDP. It can also be used as an effective tool for fiscal policy management if implemented successfully, due to nation-wide same tax rate. The ‘flawless’ GST is designed as a consumption type destination-based VAT with invoice credit method. It will help to optimize efficiency, equity and effectiveness. Several governments have come and gone, each with different promises and goals.
(Poirson, 2006) In its working paper on “The Tax System in India: Could Reform Spur Growth” has stated that a tax reform combining lower statutory rates with base broadening could help in achieving a pro-growth of fiscal adjustment in India. He also states that tax productivity estimates suggest ample scope for raising direct tax revenue through the removal of exemptions and improved tax administration and compliance.
(Sui & Loi, 1994) In their article titled “Implementation of the Goods and Services Tax (GST) in the Singapore Construction Industry” they studied on the problems and changes which building contractors in the construction industry have made to accommodate the implementation of this tax, for which they concluded that larger construction companies in Singapore spent more time and effort in preparing for the implementation of GST than smaller construction companies.
Research Gap
Although at International level some studies compare Indian GST with another countries. As far as our knowledge and review of literature is concerned very few studies has been carried to compare the GST of Singapore and India. Further no such comparative study of the laws of two countries have been done in past to learn from experience of Singapore. In this way present study fulfils this research gap.
Research Methodology
For the purpose of this study we have been taken as the law of GST of India and Singapore. The GST Taxation Law with its working were compared with the help of some of the key points of the statue. Comparative Charts are drawn to help in easy understanding of the law, enactment, working of the two countries.
This research work is fully based on secondary data from various sources like reference books, articles from newspapers, research papers, talks in the parliament and various websites.
India and Singapore both being the countries of Asian Continent, where Singapore leads the ally of GST implemented Nations in the continent, so to learn from the experience of the Singapore wherein they have been successfully doing this with the lowest rate for so long years. Therefore, on the judgemental basis we have selected Singapore for the purpose of this study.
Objectives of The Study
The primary objectives of the paper are:
- I. To study and compare about Goods and Service Tax law of the two selected counties of Asia, with respect to enactment, working and to critically comment on the same.
- II. On the basis of comparison, give suggestions which can be useful in overcoming the current and future difficulties being faced by India in successful implementation of GST across the nation.
Comparative Study of GST Law of India and Singapore
1. At a Glance
| Particulars | Singapore | India |
|---|---|---|
| Name of Law | Goods and Services Tax | Goods and Services Tax |
| Date of Implementation | 01 – 04 – 1994 | 01 – 07 – 2017 |
| Governing Acts | Goods and Services Tax Act, 1993. | India has adopted and implemented Dual model of GST, which are as follows: Central Goods and Services Tax Act, 2017, State Goods and Services Tax Act, 2017, Union Territory Goods and Services Tax Act, 2017 & Integrated Goods and Services Tax Act, 2019. Consequently, we have taken Central Goods and Services Tax Act, 2017 and Integrated Goods and Services Tax Act, 2017, for the purpose of this study. |
| Threshold and Exemption Limit from Registration. | Business whose gross receipt/ turnover is less than SGD 1 Million (Approximately 5.30 Cr), can claim exemption from registration under the GST Act. | Business whose gross receipt/ turnover is less than 20 Lakhs (10 Lacs in case of North Eastern States), can claim exemption from registration under the GST Act. |
| Registration for various branches or different offices of a group. | Group Registration. Businesses that are under “common control” may apply to register as a GST group. Each member must be individually registered for GST. After group members are registered as a GST group, they are treated as a single taxable person and submit a single GST return. Supplies made between members within the same GST group are disregarded for GST purposes. Group members are jointly and severally liable for all GST liabilities. | There is no such concept of group registration/ single registration/ centralised registration in India. In India branches are required to take separate registration on each territory/ state basis, however entire branches under that territory can operate on that single registration, but they can not take a centralised registration for the business as in whole which is operating in multiple locations in different states. |
| Standard Rate of GST | Singapore operates on single rate of Taxation – wherein its standard rate of GST is 7%, in current. At the time of introduction of GST, the rate was 4%. Zero rated exempted supplies as enlisted and specified. Further on a list of specified items there are Zero Rated exempted supplies too. |
India adopted a multiple slab system taxation, wherein the products have been specified and classified on the basis of HSN code and are taxed at 0% (for food staples), 0.25%, 3%, 5%, 12%, 18% and 28% (+cess for luxury items). Further the highest rate for a GST has been fixed under the act as 28%, but the other powers in hands of council, which can be changed on the recommendation of GST council. |
| Returns and Payment of Taxes | Quarterly Return in form of a summary return through GST F5 is to be filed. In case where there is no liability to pay taxes, being an exporter, and there arises a refund always, then assessee can file his return on monthly basis, with a prior approval. |
Monthly Summary Return GSTR 3B is to be filed along with payment of taxes, Further a detailed GSTR 1 return for outward supply too is required to be filed on Monthly basis, with an option in case where turnover is less than 1.5 Crore in last Financial Year, than assessee can choose the option of filing GSTR 1 on quarterly basis. Further Returns – GSTR 2 and GSTR 3 have not, yet been notified. (But as per law they too shall be required to be filed on monthly basis). Annual Return – An annual return in form GSTR 9 is required to be filed by every registered person for the FY after the end of FY, along with an audit if the annual turnover of the said FY is more than 2 Crore. |
| Penalty for delay in submission of Return. | A penalty of SGD 200 after the submission due date and an additional SGD 200 for each completed month are assessed for the late submission of a GST return, up to a maximum penalty of SGD 10,000. | Penalty for late filing of every return shall be levied on daily basis with maximum cap of INR 10,000, per return. |
| Interest and Penalty for delayed Payment of Taxes. | A flat penalty of 5% of the tax due is levied for late payment of taxes. Further if the delay is more than 60 days, than an additional penalty is @ 2% of the tax due for each completed month is levied, up to a maximum of 50% of the unpaid tax. That implies - that maximum penalty and Interest chargeable in case of any delay due to dispute will not rise beyond 55% of the total tax due. |
Interest @ 18% pa shall be charged for the time, till there is default in payment of taxes. Further if the liability of taxes arises due to wrong utilization/ excess utilization of input tax credit, or undue/ mis-statement of output taxes, then interest shall be levied @ 24% pa, for the period till which default continues. It is important to note, that there is no celling/ capping on the amount of interest being levied because of delayed payment, further no relief in case of disputed matter being confirmed at a later stage, thus in times the amount of interest can surpass the total amount of tax due too. |
2. Scope of Taxation
Singapore
As per Goods and Services Tax Act, 1993, (31 of 1993), of Singapore: -
“As per Section 7 – Goods and services tax
A tax shall be charged on the supply of goods and services (including anything treated as such a supply) and on the importation of goods.
As per Section 8 – Scope of Tax
Forward Charge – Tax shall be charged on any supply of goods or services other than an exempt supply made where it is a taxable supply made by a taxable person in the course or furtherance of any business carried on by him.
Reverse Charge – Tax shall be charged on Reverse Charge Basis on Import of services from abroad by a person for the purpose of his business.
As per Section 10 - Meaning of “supply”
(a) “supply” in this Act includes all forms of supply and reverse charge supplies, but not anything done otherwise than for a consideration;
(b) anything which is not a supply of goods but is done for a consideration (including, if so done, the granting, assignment or surrender of any right) is a supply of services.
As per Section 2 – Interpretation
“goods” excludes money
“Services” is anything which is not a supply of goods and is done for a consideration (including, if so done, the granting, assignment or surrender of any right).
“Money” and “Currency” include currencies whether of Singapore or any other country but does not include a collector’s piece, investment article or item of numismatic interest.”
India
As per Central Goods and Services Tax Act, 2017, (12 of 2017), of India: -
“As per Section 9 – Levy and Collection
Forward Charge – GST shall be levied on all supply of goods or services or both, within country, except on the supply of alcoholic liquor for human consumption, on the value determined under section 15 and at such rates, not exceeding twenty per cent., as may be notified by the Government on the recommendations of the Council and collected in such manner as may be prescribed and shall be paid by the taxable person.
Reverse Charge –
a) The GST on specified categories of supply of goods or services or both shall be paid on reverse charge basis by the recipient of such goods or services or both and all the provisions of this Act shall apply to such recipient as if he is the person liable for paying the tax in relation to the supply of such goods or services or both;
b) GST in respect of the supply of taxable goods or services or both by a supplier, who is not registered, to a registered person shall be paid by such person on reverse charge basis as the recipient and all the provisions of this Act shall apply to such recipient as if he is the person liable for paying the tax in relation to the supply of such goods or services or both.
As per Section 7 – Scope of Supply – The expression “supply” includes –
(a) all forms of supply of goods or services or both such as sale, transfer, barter, exchange, licence, rental, lease or disposal made or agreed to be made for a consideration by a person in the course or furtherance of business;
(b) import of services for a consideration whether or not in the course or furtherance of business;
(c) the activities specified in Schedule I, made or agreed to be made without a consideration; and
(d) the activities to be treated as supply of goods or supply of services as referred to in Schedule II.”
As per Section 2 - Definitions
“goods” means every kind of movable property other than money and securities but includes actionable claim, growing crops, grass and things attached to or forming part of the land which are agreed to be severed before supply or under a contract of supply.
“services” means anything other than goods, money and securities but includes activities relating to the use of money or its conversion by cash or by any other mode, from one form, currency or denomination, to another form, currency or denomination for which a separate consideration is charged.
“money” means the Indian legal tender or any foreign currency, cheque, promissory note, bill of exchange, letter of credit, draft, pay order, traveller cheque, money order, postal or electronic remittance or any other instrument recognised by the Reserve Bank of India when used as a consideration to settle an obligation or exchange with Indian legal tender of another denomination but shall not include any currency that is held for its numismatic value.”
Remarks:
The law of two countries in veneration of inclusive thoughtfulness is more or less matching, but the aspect of elucidations and definitions as covered in the act showcases a great deal of contrast. The scope for coverage and its related terms are defined in one or two liners under the statue of Singapore, on the contrary, the Indian statues are elaborative, which are good in the initial stages and are easier to comprehend.
Term “Goods” as defined in the two country has a very wide difference, Indian legislature covers only movable properties as goods, whereas in case of Singapore it covers all movable and immovable properties, with a similar exclusion by both of money and currency, with additional exclusion in India of Shares and Securities.
The Term “Services” has been defined simply under both the laws as anything other than goods, but again India in this case has tried to cover some additional business with express statement in the statue.
Similarly, there has been much more the definition of money and currency has too been elaborated extravagantly, covering the financial instruments like travels cheque, LC’s etc. with a specific coverage, leaves an ambiguity, for an example what if the item is a bearer cheque and the same is exchanged or endorsed, will that be a goods for the purpose of GST, so this leaves ample scope and may raise questions’ with the passage of time and with the fast changing business environment, while on the other hand defining a item in plain essence with least if and but, and to define it word “include” gives an wide meaning with ample scope of bringing all in its ambit, which can be understood in common parlance, or that has been defined in any other law of the land.
On the hands of charging section, both the countries charge tax on both forward and reverse basis, but in India the same is extensive an regressive, further when there is a particular section which says that in case of purchases from unregistered person the taxable person is liable to pay tax on same on RCM basis, this enough is sufficient, but introduction of separate specified list, that too notification based, lives ample scope for ambiguity and confusion over status, the notification can be amendment as and when required and there can be instances that people might not get updated with the same and this can lead to some non – compliances, penal consequences etc., therefore the proviso should not be recurrent in the act, that one needs to look into the aspects of drawing harmonious construction of the statues.
3. Time of Supply
Singapore
As per Goods and Services Tax Act, 1993, (31 of 1993), of Singapore: -
“As per Section 11 – Time of Supply – For Forward Charge Supply
A supply of goods or services shall be treated for the purposes of this Act as taking place at the time when — the person making the supply issues an invoice or receives any consideration in respect of it; whichever is earlier.
As per Section 11C – Time of Supply – For Reverse Charge Supplies
Where the recipient receives services, which are subject to reverse charge supplies, as taking place at the earlier of — (a) the date on which supply is made to the recipient; and (b) the date on which any consideration is paid for that supply, to the extent that the supply of services is covered by the entry or consideration.”
India
As per Central Goods and Services Tax Act, 2017, (12 of 2017), of India: -
“As per Section 12 – Time of Supply of Goods – For Forward Charge Supply
Time of supply of goods shall be earliest of the following dates: — (a) date of issue of invoice; or (b) last date on which supplier is required to issue invoice; or (c) date of payment.
As per Section 12 – Time of Supply of Goods – For Reverse Charge Supply
Time of supply shall be earliest of the following dates: — (a) date of receipt of goods; or (b) date of payment; or (c) date on which payment is debited in bank account; or (d) thirty first day from date of invoice.
As per Section 13 – Time of Supply of Services – For Forward Charge Supply
Time of supply of services shall be earliest of the following dates: — (a) date of issue of invoice; or (b) date of receipt of payment; or (c) date of provision of service; or (c) date of receipt of services in books of account.
As per Section 13 – Time of Supply of Services – For Reverse Charge Supply
Time of supply shall be earliest of the following dates: –– (a) date of payment; or (b) date on which payment is debited in bank account; or (c) sixty first day from date of invoice.
As per Section 12 & 13 – Time of Supply for - Interest, Late Fee or Penalty for delayed payment of any consideration
Time of supply in case of interest, late fee or penalty for delayed payment of any consideration – it shall be the date on which the supplier receives such addition in value.”
Remarks:
Singapore considers the time of supply is the moment, where liability of tax shall be determined at a date which is earlier of accrual or payment, whichever is earlier. Whereas India has been a step ahead in clarifying the charging moment of a transaction as Time of Supply separately for both goods and services, where the liability of tax will be the date, date of accrual or date of payment or last date at which it could get accrue as per act, whichever is earliest. Further in case of any amount which is charged as an additional levy because of default in payment etc, then in such cases, the time of supply shall be the date when amount is actually recovered will be considered, just accruing of the same in books shall not be liable for actually taxing the same, this additional point is good and infact better as compared to that from Singapore, as where there is default of the principal amount, the recovery of additional levy cannot be confirmed, and hence the same should be taxable only when actually received, thus, Indian statue is better in this term.
Herein the Indian statue, even though extra elaborative has cleverly drafted the provision where the interest of business houses in practical essence too have been taken care off, along with the defaults, if any, made by any business house because of any its system hierarchy, and in case of business disputes too, there will be no loss of taxes to government for the original amount.
The length and complexities of law of India could have been reduced, by making similar law for both supply of goods as well as services, and thus by just defining them through the use of single term “Time of Supply”. This would have even dropped out the possibilities of the cases, where there have been many disputes in past, that whether a particular transaction is covered under goods or services, i.e. in case of a composite transaction.
4. Input Tax Credit
Singapore
As per Goods and Services Tax Act, 1993, (31 of 1993), of Singapore: -
“As per Section 19 – Input Tax Credit
“input tax”, in relation to a taxable person, means the following: (i) tax on the supply to him of any goods or services; (ii) tax on the reverse charge supply treated as made by him (as a recipient) to himself; (iii) tax paid or payable by him on importation of any goods, being (in any such case) goods or services used or to be used for the purpose of any business carried on or to be carried on by him.
As per Section 19 - Apportionment of credit/ Restrictions
Wherever any registered person uses the goods or services for any purposes other than business, than tax on such supplies and importations must be apportioned and credit of only so much input tax shall be allowed as is attributable to business.”
India
As per Central Goods and Services Tax Act, 2017, (12 of 2017), of India: -
“As per Section 16 – Input Tax Credit
Every person shall be entitled to take credit of tax charged on any supply of goods or services or both which are used or intended to be used in course or furtherance of business.
As per Section 17 – Apportionment of Credit
(1) Where goods or services or both are used by person partly for any purposes other than the business, then the amount of credit shall be restricted to so much of the input tax as is attributable for the purposes of business.
(2) Where goods or services or both are used by person partly for effecting taxable supplies including zero-rated supplies and partly for effecting exempt supplies, then amount of credit shall be restricted to so much of the input tax as is attributable to the said taxable supplies including zero-rated supplies.
(3) A banking company or a financial institution including a NBFC, engaged in supplying services by way of accepting deposits, extending loans or advances shall have option to either comply with the provisions of sub-section (2) above, or avail of, every month, an amount equal to fifty percent of the eligible input tax credit on inputs, capital goods and input services in that month and the rest shall lapse.
As per Section 17 – Blocked Credit
Input tax credit shall not be available in respect of the following, namely: —
(a) motor vehicles and other conveyances except when they are used – (i) in making taxable supplies; or (ii) for transportation of goods;
(b) food and beverages, outdoor catering except where an inward supply is made to make outward supply in similar category;
(c) beauty treatment, health services, cosmetic and plastic surgery except where an inward supply is made to make outward supply in similar category;
(d) membership of a club, health and fitness centre;
(e) rent-a-cab except where –– required under statutory obligation or in same line of business;
(f) life insurance and health insurance except where –– required under statutory obligation or in same line of business;
(g) travel benefits extended to employees on vacation such as leave or home travel concession;
(h) works contract services when supplied for construction of an immovable property (other than plant and machinery) except where it is an input service for further supply of works contract service;
(i) goods or services or both received by a taxable person for construction: including re-construction, renovation, additions or alterations or repairs, to the extent of capitalisation:, of an immovable property (other than plant or machinery) on his own account including when such goods or services or both are used in the course or furtherance of business;
(j) goods or services or both for which tax is paid under composition scheme;
(k) goods or services or both received by a non-resident taxable person except on goods imported by him;
(l) goods or services or both used for personal consumption;
(m) goods lost, stolen, destroyed, written off or disposed of by way of gift or free samples; and
(n) any tax paid in matter of confiscation and penal provisions.”
Remarks:
In case of input tax credit, the law of India is too complex, there are several restrictions and several prohibitions for a tax to be eligible input tax credit, whereas the law of Singapore is very clear and straight forward at this front too, it allows every item to be claimed as input tax credit, provided the same has been paid and used in course of business, with no other condition and restriction, thus making it simple and clear, whereas in case of Indian Law even if the fundamentals are more or less clear, but the law makers have induced many tangles and restriction for various capital expenditure and other revenue expenditures which are incurred by a business house in the course of furtherance of his business, but the same have been specifically categorised as a blocked credit and thus not allowed, therefore even after the introduction of the system of GST, the complexities of allowability of taxes credit remains same with and the wipe off the cascading effect of taxes, have been reduced but not fully eliminated from the system.
The allowability and seamless flow of the input tax credit in the system is the main essence of the GST, further this encourages the business houses to think innovatively and take on the big decisions in capital investment, with a possibility of quick payback period, a better IRR. Further this would not just facilitate the business houses, but it will help the economy to be more competitive in the world market, as the prices of the products shall surely go down. Benefits of this would just not be restricted to a particular industry, but will flow through the economy and will also help in reducing the unemployment.
Therefore, a clear provision in India with respect to input tax credit to be in line with those as enacted in the statue of Singapore would surely help to make the law of India not just easy to understand but also easy to work upon with a boast to the mission of Make in India. And this will not just reduce litigations and chance of litigations, but also the matter of assessments would by department would become very easy as the matter of only correct rate determination at output would be required to be checked, and thus in turn would also reduce the department’s administrative aspect.
Conclusion and Recommendations
India has overcome the muddle of many taxes, which was hindering the growth of the industry. However, rudimentary aim of a reform should be to streamline and simplify the working of statute. The Indian law of GST, has taken big leap forward in the direction, however, can be further updated to bring certain more benefits to tax payers. There are areas that can be modified to give better experience. The burden of tax compliance as compared to that of Singapore is complex and with high frequency, this is a hurdle in the vision of government to provide ease of doing business and eliciting the foreign investment for setting up industries to achieve the mission of Make in India. Furthermore, in long run when we try to look into the aspects the act together with various judicial pronouncements and interpretations of the different intellectuals the inferences would be drawn in such a manner as beneficial to one’s own business.
There is a sturdy requirement for a thoughtful review and actions from the government in streamlining the GST structure. A country’s economic progress is hugely depended on the type of taxation structure it adopts. There is a need that both the central and state governments cohesively work together to further simplify the the taxation structure with uniform common objectives. GST has brought paradigm shift in Indian Indirect taxation regime and over time with modifications is going to be a genuinely uncomplicated tax system, much more than what it is now. It would further the objectives of Government to bring ease of doing business besides augmenting much needed financial resources.■
Bibliography
- Gupta, S. (2017). Goods and Services Tax (GST): A Comparative Study of Select ASEAN Countries. VISION: Journal of Indian Taxation, 4. doi:10.17492/vision.v4i01.9995
- Gupta, S., Sarita, Singh, M. K., Komal, & Kumawat, C. (2017, May). Good and Service Tax: An International Comparative Analysis. International Journal of Research in Finance and Marketing, pp. 29-38. Retrieved from http://euroasiapub.org/current.php?title=IJRFM
- Kumar, S. R., Revankar, V., & Jaju, D. (2018, March). GST: A Comparative study of India vis a vis Singapore. Journal of Management Research and Analysis, 05(01), 136-141.
- Pathan, H. S. (2017, October 05). A Comparative Study of GST in India and Other Countries. International Journal of Research and Analytical Reviews, 4(4).
- Poirson, H. (2006). The Tax System in India: Could Reform Spur Growth? https://www.imf.org/external/pubs/ft/wp/2006/wp0693.pdf.
- SAG Infotech. (2019, 12 10). Difference Explained: GST India vs GST in Other Countries. Retrieved 12 12, 2019, from SAG Infotech Blog: https://blog.saginfotech.com/gst-india-vs-foreign-gst
- Sui, P. L., & Loi, C. P. (1994, 01 01). Implementation of the Goods and Services Tax (GST) in the Singapore Construction Industry. Journal of Property Finance, 5(3), 41-58. Retrieved from https://doi.rg/10.1108/09588689410078593
- Goods and Services Tax Act, 1993, (31 of 1993) & Rules thereunder, of Singapore
- Central Goods and Services Tax Act, 2017, (12 of 2017) & Rules thereunder, of India
- Integrated Goods and Services Tax Act, 2017, (13 of 2017) & Rules thereunder, of India.