VAT Terminology and Rates – a Recap 13 VAT Terminology Output Tax • VAT charged by businesses on sales made to their customers • “Output” meant to reflect outgoing sales Input Tax • VAT spent by businesses on qualifying business expenditures • “Input” meant to reflect incoming purchasing Supply Consideration Reverse Charge Mechanism • VAT terminology for a “sale” • Goods: tangibles; Services: intangibles • Payment received in return for the supply of goods or provision of services • Generally, “everything received in return for the supply of goods and services,…” • Situation in which seller of services (usually foreign) is not liable for VAT, and instead buyer is required to account for VAT Note the focus on movement on goods/services, rather than movement of money © 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Not for distribution to clients unless the technical and policy review requirements of Tax Services Manual section 23.7 are satisfied. 14 7 VAT Rates Standard • EU VAT rates range from 15% to 27%. Average EU VAT rate is approaching 21.5%—somewhat less in ASPAC and LATAM Reduced • Any rate lower than the standard rate • E.g., basic food stuff, books—usually political decision Zero-rated • No VAT is charged, but seller HAS a right to credit input tax • E.g., exported goods and services Exempt • No VAT is charged, but the seller HAS NO right to credit input tax • E.g., certain financial, medical and education services Outside Scope • Not within the scope of VAT in the jurisdiction concerned • E.g., charities and non-business © 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Not for distribution to clients unless the technical and policy review requirements of Tax Services Manual section 23.7 are satisfied. 15 Global Trends and Developments 8 Global Challenges Import valuation issues Sourcing changes for e-services Importer of record must be owner to recover VAT Proposed Sourcing changes for e-services Current reform Cashflow VAT system Proposed reform Introduction in April 2015 Multiple indirect taxes and jurisdictions VAT credits vs. refunds Import restrictions Difficulties with VAT refunds Various rate changes © 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Not for distribution to clients unless the technical and policy review requirements of Tax Services Manual section 23.7 are satisfied. 17 VAT Rate Changes – Past 12 Months, Country Effective Date Original Rate New Rate Serbia 1/1/2014 8%* 10%* France 1/1/2014 19.6%, 7%* 20%, 10%* Cyprus 1/1/2014 18%, 8%* 19%, 9%* Ghana 1/1/2014 12.5% 15% Mexico 1/1/2014 11% border region 16%, Standard Honduras 1/1/2014 12% 15% Japan 4/1/2014 5% 8% Dominican Republic 1/1/2015 18% 16% Ukraine 1/1/2015 20% 17% Luxembourg 1/1/2015 15%,12%*, 6%* 17%, 14%*, 8%* Czech Republic 1/1/2015 21%, 15%* 21%, 15%*, 10%* Source: WNT Research * Reduced VAT rate © 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Not for distribution to clients unless the technical and policy review requirements of Tax Services Manual section 23.7 are satisfied. 16 9 Global VAT/GST Expansion China started in 2011 a reform to replace its business tax with a VAT Jurisdictions that have recently introduced a VAT/GST − Full VAT is expected to be in place by the end of 2015 for all of China − Bahamas (Jan. 1, 2015) − Malaysia (Apr. 1, 2015) to replace sales and services tax Potential introduction − Egypt: plan to replace current sales tax with a VAT by January 2016? − India: plan to replace current complex indirect tax system with a GST by April 2016? Others − Gulf Cooperation States: undergoing discussions of a VAT framework agreement − United States: included in certain discussions for a comprehensive tax reform (based on the Canadian GST model?) © 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Not for distribution to clients unless the technical and policy review requirements of Tax Services Manual section 23.7 are satisfied. 19 Global Shift in VAT/GST Taxation of Services The Organisation for Economic Co-operation and Development (OECD) is working on International VAT/GST Guidelines − Business-to-business (B2B) transactions Guidelines on B2B international services that were finalized in 2014 and have already been endorsed by over 100 countries B2B services should generally be taxed where the service recipient is located Renewed focus on ensuring that VAT exempt businesses are also subject to these rules and the potential to exploit mismatches in taxation are phased out − Business-to-consumer (B2C) transactions Draft guidelines have been released for comments on December 18, 2014 Remote sellers of electronic services to final customers may be required to register and remit VAT/GST in the country where the final customer is resident In addition to the European Union, Iceland, Switzerland, Norway, Ghana, Kenya, South Africa, and Albania more jurisdictions are looking into new VAT/GST rules on e-services • Korea (Jul.1 , 2015); Japan (Oct. 1, 2015) • Australia, New Zealand, Canada? © 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Not for distribution to clients unless the technical and policy review requirements of Tax Services Manual section 23.7 are satisfied. 20 10