Tamilnadu Local Authority Entertainment Tax Act 2017

TN LOCAL AUTHORITY ENTERTAINMENT TAX ACT 2017

After GST came into force on July 1, it subsumed the state government-levied entertainment tax on cinema tickets, which was 20% on average, across the nation. GST is levied at 28% for movie tickets priced above Rs 100, while the GST rate on tickets below Rs 100 is 18%. Through a Constitutional amendment, local bodies are permitted to levy entertainment tax.

Soon after GST came into effect, governments in Rajasthan, Gujarat, Maharashtra, Tamil Nadu and Kerala passed legislation authorising their local bodies to begin levying local body entertainment tax. However, so far, only Chennai has actually levied it.

The local body entertainment tax in Chennai is being levied at 8% for Tamil movies, 15% on non-Tamil Indian movies and 20% on English movies. For multiplex majors such as INOX Leisure Ltd and PVR Cinemas, whose theatres are shut in Chennai, Hindi and English films constitute a major part of the market. The entertainment tax on these movies have effectively risen to between 48% and 53%

Constitutional provision

The GST 101 constitutional amendment made two provision with regards to taxing on entertainment 1. Entertainment activity which were held with state list were subsumed unger GST 2. Taxing levy power given to Local body to impose tax on entertainment activity held in their jurisdiction of Panchayat & Municipality, In order to made this changes, government made change in the entry no. 62 of VII Schedule State list under Indian constitution.

´ Previous Entry: “Taxes on luxuries, including taxes on entertainments, amusements, betting and gambling” 

´ Currently modified as: “Taxes on entertainments and amusements to the extent levied and collected by a Panchayat or a Municipality or a Regional Council or a District Council

Definition & Authorities[1]

All the definition held in previous act i.e TN Entertainment tax act 1939 taken in this act. Important definitions are

Sec 2(8):- “entertainment” means a horse-race or cinematography exhibition to which persons are admitted on payment or television exhibition for which persons are required to make payment by way of contribution, or subscription, or installation or connection charges or any other charges collected in any manner whatsoever or an amusement or a recreation parlour where a game such as bowling, billiards, snooker or the like is provided or direct to home service or a cricket tournament like the Indian Premier League or the Champions League Twenty 20 cricket tournament conducted by the Board of Control for Cricket in India or any other sports tournament conducted by any person or body of persons for which persons are required to make payment for admission.

Sec 2(11) :- “Local authority” means

(a) a municipal corporation established under any law for the time being in force;

(b) a municipality or town panchayat constituted under the Tamil Nadu District Municipalities Act, 1920; or

(c) a village panchayat constituted under the Tamil Nadu Panchayats Act, 1994, in whose jurisdiction the entertainment is provided;

Power to levy tax

As per Section 3 of the Act, the local authorities have been given the power to levy tax on the following entertainments, namely: - 

  • Cinematograph exhibition in the theaters;
  • Horse-race;
  • Cinematograph film exhibited on television, screen through Video Cassette Recorder or through Cable Television Network;
  • Television exhibition;
  • Amusements;
  • Recreation parlour;
  • Entertainments provided by direct to home service;
  • Cricket tournament or any other tournament

Tax rates under tnlaet 2017

CATEGORY

 

TAX RATE

ET on cinema exhibition in theatres

New Tamil Films

8%

 

New Films (Other language)

15%

 

New Films (English & Forign language)

20%

 

 

 

 

Old Tamil Films

7%

 

Old Films (Other language)

10%

 

Old Films (English & Forign language)

14%

 

 

 

ET On Amusement

 

10%

 

 

 

ET on Recreation parlour

 

20%

 

 

 

ET on cricket and other tournaments

 

25%

 

 

 

TAX CALCULATIONS

CATEGORY

RATE OF TICKET / ADMISSION

CGST

SGST

LBET

TOTAL

Cinema exhibition in theatres

                                                 150.00

                         13.50

             13.50

         12.00

         189.00

 

 

 

 

 

 

Amusement

                                                 500.00

                         45.00

             45.00

         50.00

         640.00

 

 

 

 

 

 

Recreation parlour

                                                 500.00

                         45.00

             45.00

       100.00

         690.00

 

 

 

 

 

 

Cricket tournaments

                                              1,000.00

                       140.00

          140.00

       250.00

      1,530.00

 

DOUBLE TAXATION

After seeing the calculation, we will have doubt that, we are paying tax twice for the same supply? Your doubt may be right, but in the legal view there is another angel to see it,

The justification given to impose two taxes for single service are, 1. Experience of theatre is one service and 2. Exhibiting movie is separate service, hence legislature are saying here is two different service are involved, hence imposing two different taxes are not leads to double taxation. The same opinion was given as judgement in two different case.

Radhakisan Rathi vs Additional Collector Durg And Ors 597 of 1975

This is was the first case judgement confirming the above view

“It may be mentioned that cinema theatre situated within a local area the concerned Municipal Council or the Corporation, as the case may be, may impose cinema tax as permissible under the Municipal Act but on the same theatre entertainment tax can be imposed by the State Govt. in exercise of its separate legislative power and there would be no occasion for the cinema owner to submit that the theatre is subjected to double taxation”

 

Balaji Theatre vs The Chief Secretary W.P. No.33077 of 2018

This is judgement came out after gst implementation, here court has confirmed in the year 2018 that GST imposing for different service and Entertainment tax levied by local body for another subject, hence there is no question of double taxation.

“In this case, providing admission into the Cinema theatre is treated as service and thus, tax on such service is collected under the GST Act. On such admission, the viewer gets the entertainment viz., Movie and thus, such entertainment being a different content, tax is levied on the same by the local authorities as "Entertainment Tax". Thus, the entertainment itself being a different content, will not fit into the act of service provided by the theater owner viz., admission of the viewer into the cinema hall. Therefore, the question of subsuming the entertainment tax under the PGST Act, or the event of double taxation as contended by the petitioner, does not arise in this case”


Pre-GST and Post-GST comparison will be shared in the next post..

                                    to be continued...

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