Comparative Study of GST Management in India and Other Countries

This article is written by Miss Anshika Trivedi, MBA 1st year student from NMIMS Mumbai and Mr Ayush Bajpai, LLB final year student from C.S.J.M Kanpur.


GST(1) aims to combine all taxes into a single tax with a smooth ITC,(2) and it would be levied on both goods and services. As a result, the tax is projected to reduce the concept of "tax on tax," raise the economy's gross domestic product, and lower prices. An examination of the influence of the GST (Goods and Services Tax) on the Indian tax system. The need for a shift in tax structure from the old to the GST model developed as a result. The influence of GST in India's current tax situation. In 1860, India was subjected to a modern-day tax structure devised by Sir James Wilson for the British Indian government of the time to recoup damages suffered during the insurrection of 1857. Since then, many measures have been implemented to control the rate of development and expand the income horizon for the government through taxes. In India, the Goods and Service Tax (GST) was recently implemented, incorporating more than 15 indirect levies and becoming one of the most active and well-known tax reforms in recent history. GST is a promising tax regime that was adopted to make Indian businesses more globally competitive by removing cascading effects, facilitating inter-state trade, bringing small enterprises into the formal economy, and reducing tax terrorism(3), among other things. It is said to be one of the most effective ways to reduce both direct and indirect tax evasion. In 1954, France became the first country in the world to implement the GST. However, as global trade has developed, more than 160 countries have embraced this taxation scheme.


The Goods and Services Tax (GST) is a tax that applies to both goods and services. On a national level, the Goods and Service Tax is levied on services and goods to achieve overall economic growth. GST is primarily intended to replace the Centre's and States' indirect taxes(4) on goods and services. GST will be an indirect tax that will be applied at all stages of production to ensure that the system is uniform. The final tax is paid by the consumer in this method. In India, the central and state governments levy a variety of taxes on goods and services. Value Added Tax, Service Tax, Excise Duty, Customs Duty, and other indirect taxes must be paid by Indian customers on goods and services. Each state imposes its tax on goods entering under its control for sale and consumption, whereas the federal government imposes taxes on the items' manufactured. All of the direct taxes imposed on merchants are passed on to the consumer. The GST treats the country as a single organism. The Indian government has decided to implement a dual-system GST. This system will be made up of two parts, which will be referred to as. State Goods and Service Tax (SGST) and Central Goods and Service Tax (CGST) (SGST).


The GST was announced by the President(5) of India and the Government of India at midnight on July 1, 2017. The launch was commemorated by a record midnight session of both houses of parliament held at the Parliament's Central Hall (30 June – 1 July). Despite the presence of high-profile guests from the business and entertainment industries, including Ratan Tata, the opposition boycotted the session owing to the anticipated hardships it would cause for India's middle and lower classes. The Indian National Congress, on the other hand, was vehemently opposed to the tax. The declaration of India's independence on August 15, 1947, and the silver and golden jubilees of that occasion are among the rare midnight sessions held by the parliament. The GST rates have been changed several times since its inception, the most recent of which being on December 22, 2018, when a panel of federal and state finance ministers opted to change GST rates on 28 goods and 53 services. The GST rollout was completely boycotted by Congress. Trinamool Congress, Communist Party of India, and DMK members joined them. The parties said that there was little difference between the GST and the current taxation system and that the government was simply seeking to rebrand the current system. They also claimed that the GST would raise current rates on everyday commodities while lowering rates on luxury items, causing harm to many Indians, particularly those in the middle, lower-middle, and lower-income groups.


Global financial institutions/industries, sectors of the Indian media, and opposition political parties in India have all attacked the technicalities of GST implementation in India. The World Bank's 2018 India Development Update criticized India's version of GST as "too complex," pointing out several faults when compared to GST systems in other nations, including the country's second-highest tax rate, at 28 percent, among a sample of 115 countries. Indian businessmen have also questioned the GST's rollout in India, citing issues like tax refund delays and the requirement for excessive documentation and administrative labor. When the first GST returns were filed in August 2017, the system crashed under the weight of the files, according to a partner at PwC(6) India. The opposition Indian National Congress has been one of the most vociferous opponents of GST implementation in India, with Rahul Gandhi, the party's president, and the opposition's leader, accusing the BJP of "killing small businesspeople and industries" in the country. He went on to call GST "Gabbar Singh Tax," after a notorious Bollywood dacoit. Rahul has branded the GST implementation a "huge failure," claiming that it is a "means of stealing money from the pockets of the poor," and that if the Congress party is elected to power, it will impose a single slab GST instead of multiple slabs. Rahul has upped his "Gabbar Singh" critiques of Modi's administration in the run-up to elections in numerous states throughout India.

Comparison of GST in India with other major countries

    1. GST in India vs GST in New Zealand

New Zealand was the first country to implement GST in 1986, with a 10% rate. However, the rates were increased again in 1989, with 12.5 percent in 1989 and 15 percent in 2010, to create more income while addressing tax structure inefficiencies.

Furthermore, this move resulted in the implementation of a single-rate GST, which included food in the GST base at the full rate. As a result, the tax net became more broad-based, lowering both compliance and administrative expenses. Currently, among the OECD countries, the country has the greatest tax productivity.

  1. GST in India vs GST in Canada

When it comes to the GST system in Canada, it was established in 1991 as a multi-level VAT on the supply of goods and services acquired in the country. The GST covers practically all things, except for a few necessities such as food, residential rent, and medical services.

Furthermore, once the law is enacted, it will lead to new processing activities and ways for verifying the correctness of small business returns. Canada, on the other hand, has its own sales tax in addition to the GST.

On supply of goods and services, the GST rate in Canada is 5%, while in some provinces, a 15 percent harmonized sales tax exists.

  1. GST in India vs GST in Singapore

The GST bill was first submitted in April 1994, with a 3% tax rate. The goal was to increase the public acceptability of the currency while lowering inflation. The administration promised the people that it would not raise the tax for the following five years, which was a key choice in recovering consumer spending. With effect from 2007, the GST rates were raised to 7%, which is still quite low when compared to the GST rates in India.

  1. GST in India vs GST in Indonesia

Imports are now normally subject to VAT and GST in Indonesia, whereas most exports are excluded from the list. If services are provided outside of Indonesia's borders, the tax rate is 10%; nevertheless, in rare situations, a specific item is taxed at 20% with a ceiling of 35%.

Moving on to luxury products, the tax rate on importation ranges from 10% to 50%. The majority of things supplied in hotels, such as gold, mining products, arts and entertainment, education, insurance, parking or public transportation, labour, medical health, food, and beverage, are not subject to VAT.

  1. GST in India vs GST in Australia

In Australia, the GST is a federal tax(7) that is collected by the highest authority and then distributed to the states without any verbal sparring. The GST was first implemented in 2000, with a tax rate of 10%, which is still in effect today.

  1. GST in India vs GST in the USA

We all know that the United States is a federal republic, which means that taxes are collected separately from the federal, state, and municipal governments. In the United States, federal tax rates range from 10% to 39.6% of taxable income. The state or local government levies a tax ranging from 0% to 13.30% of total taxable income.

  1. GST in India vs GST in U.K

For products and services, there are three tax rates: zero percent, five percent, and twenty percent. The majority of the commodities are subject to a 20% tax rate. Exempted products include stamps, postage, financial property transfers, food, and children's clothing.

  1. GST in India vs GST in Brazil

In comparison to other GST systems, Brazil's GST system is the most independent and unconstrained. It has separated tax regulations between the states and the federal government. The six tax slabs in Brazil are as follows: 0%, 1.65%, and 2%. 7 percent, 13%, and 17%, respectively

  1. GST in India vs GST in France

France was the first country(8) to implement the GST. The GST was initially established in 1954 in France, with four tax rate levels. In this county, the rates are charged in slabs of 2.1 percent, 5.5 percent, ten percent, and twenty percent. The standard rate of taxation in France is 20%, which applies to the majority of items.

  1. GST in India vs GST in Ukraine

In Ukraine, a 20 percent standard rate of tax is implemented, and the VAT value is added to the price of products and services. Some of the suppliers are also subject to lesser rates of between 0% and 7%.

Pharmaceuticals, medications, and medical equipment are usually subject to GST at a rate of 7%, whereas exports of goods and services are subject to percent VAT.

  1. GST in India vs GST Malaysia

In Malaysia, the Goods and Services Tax (GST) was established on April 1, 2015, with a uniform rate of 6%. Sales tax and service tax are divided into two categories based on their tax rates, which are 10% and 6%, respectively. Some commodities are excluded from taxes, such as piped water, the first 200 units of energy each month, transportation services, highway tolls, and health services.


Due to the regressive nature of GST, maintaining a single rate will raise the cost of living, as demonstrated in Malaysia. Inequality in the population cohort will also rise, particularly in India. Furthermore, according to the latest statistics, India's top 1% own 78 percent of the country's wealth. Following Singapore's and Malaysia's single tax structure would exacerbate income inequality and worsen the issue. As a result, India has done the correct thing by introducing numerous tax bands. Apart from having numerous rates, India had an advantage over Malaysia in that its VAT regime suffered from the cascading impact of taxes because it was an origin-based tax. The SST(9) did not have a cascading effect in Malaysia. As a result, the implementation of GST in India has resulted in a reduction in the rates of most items, which did not occur in Malaysia. The complexity aspects of both regimes, however, have stayed the same. To realize the benefits of GST, India must overcome these issues.

As a result, India still has a long way to go until the GST's teething difficulties are resolved. It has, however, made a solid start and must maintain this momentum.


  1. The Central Goods And Services Act, 2017
  2. Input Tax Credit
  3. Tax terrorism is a way to terrorise honest taxpayers to pay unreasonable taxes but through legal means
  4. Indirect tax is defined as the tax imposed by the government on a taxpayer for goods and services rendered.
  5. Mr. Pranab Mukherjee
  6. PricewaterhouseCoopers Private Limited
  7. a tax that you pay to the national government, rather than to a state government
  8. France Implemented GST in 1954
  9. Sales and Services Tax

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