VAT in federal countries:
international experience
Artur Swistak
Fiscal Affairs Department
International Monetary Fund, Washington
Seminar: ICMS and the Future of the States
Guarujá, Sao Paulo, Brazil, September 16-17, 2015
Views expressed in this presentation are of the author’s and should not be attributed to the IMF, its Executive Board, or its management.
Outline
• Principles of VAT: theory and practice
– scope, method and basis
• Decentralization of VAT
– rate differentiation & revenue sharing
• Regional VATs
– issues and a handful of examples
• EU experience with VAT harmonization
– evolution, current solutions & proposals
• Alternative VAT designs:
– CVAT & VIVAT
Let’s start with
PRINCIPLES OF VAT
VAT – the tax of 21st century
• Almost unheard of 60 years ago; first introduced
in France (1954)
• Now 150+ countries have it; and its spread
continues
• Replaced distortive turnover and/or retail taxes
• Excellent revenue raiser (ca. 25 percent of world’s
tax revenue)
• A ‘good tax’ if well designed and implemented simple, efficient, neutral
Recipe for a “good” VAT:
Basic principles
• Objective: raise revenue!
• Scope:
– broad base: goods and services
– minimum exemptions/reliefs
– single positive rate
• Imposition:
– multiple stage tax (whole value chain covered)
– invoice-credit method; refunds paid
– destination basis
• Practice differs widely across countries
Weaknesses of VAT
• Equity:
– VAT a regressive tax
• Administration:
– need to pay refunds
– prone to abuse (missing trader or carousel fraud)
• Cross-border issues:
– place of supply: where to tax? to whom benefits accrue?
– VAT a national tax: how to design VAT in federations? how
to share the tax base/revenue? how to avoid competition?
how to cooperate? how to keep administrative/compliance
costs in check?
International experience
with VAT in federations
SubVAT
national Standard VAT level Federal States
Level
Rate
Argentina
Provinces
21
National Mexico
Australia
States
10
National Micronesia
Austria
Lands
20
National Nepal
Belgium
Regions
21
National Nigeria
Bosnia and Herzegovina Entities
17
National Pakistan
Brazil
States
18
Regional Russia
Canada
Provinces
5/10
Regional Saint Kitts and Nevis
Comoros
Islands
None
Somalia
Ethiopia
Regions
15
National Switzeralnd
Germany
Lands
19
National UAE
India
States
14
Regional USA
Malaysia
States
None
Venezuela
Federal States
SubVAT
national Standard VAT level
Level
Rate
States
16
National
States
None
Zones
13
National
States
5
National
Provinces
17
National
Republics
18
National
Islands
17
National
States
None
Cantones
8
National
Emirates
none
None
States
none
None
States
12
National
• Most of federations have national VATs, a few of these are
decentralized, though
• Only few operate regional VATs (Brazil, Canada, India)
• Is VAT design an impediment to adoption by those who have none?
What are the common
VAT structures?
Unitary State
Federation/
Common market
National VAT
Regional VAT
Uniform VAT
Decentralized VAT
Independent
Harmonized
Piggybacked
Territorial rates
Revenue Sharing
Sub-national
administration
Individual
Why VAT is mostly a national tax?
• Constitutional setting (taxing power)
• Common market and regional harmonization
requirements (e.g. EU)
• Policy choice due to:
– ease of design
– lower administrative effort
– more efficient macroeconomic policy:
•
•
•
•
less competition/higher productivity
preference to transfers and development equalization
national trade and other policies
planning and forecasting
Standard features of national VAT
• Uniform central policy, usually no additional
sub-national similar taxes or piggybacking
• Single legislation and jurisprudence (even if
regional nuances exist)
• Single administration and enforcement
(government tax offices)
• Central government source of revenue (even if
shared)
National VAT does not have to be that uniform
DECENTRALIZED VATS
VAT Decentralization - overview
• Countries have discretion in adopting VAT structure
• Some federations avoid “problems” with sub-national VAT
and “decentralize” it
• Degree and scope of decentralization vary
• Examples of decentralization include:
– Rate differentiation/exclusions
– Use of regional tax administrations
– VAT revenue sharing/allocation – a viable option to regional
VATs
Decentralized VAT: rate differentiation
• National VAT with reduced rates applied to specific
regions/territories
• Objective: regional development, redistribution, incentivizing some
activities or avoiding competition
• Examples of lower rates found both in federations and unitary
states:
–
–
–
–
Austria, Mexico in border regions, areas
Spain in Canary Islands, Ceuta & Melilla
Portugal in the Azores
Peru (the Amazonia)
• Examples of VAT exclusions in EU:
– Finland (Aland Islands), Greece (Mount Athos), France (e.g. Mayotte),
UK (Chanel Islands), Germany (Islands of Heligoland), Italy (e.g. Lake
Lugano), and many others – treated as non-EU for VAT purposes
Decentralized VAT: administrative
arrangements
• Regional tax authorities collect VAT on behalf
of:
– Federation, e.g.:
• Mexico – apart from administering VAT states entitled
to keep share of additional VAT (due to audits)
• Quebec – the only province to collect federal GST
– Unitary states (usually highly devolved), e.g.:
• Spain (Basque Country and Navarre)
• UK (Isle of Man)
• Tanzania (Zanzibar)
Decentralized VAT: revenue sharing
• Revenue sharing found both in federations and unitary
states (e.g. Morocco, Japan, Korea, UK)
• National VAT revenue transferred directly to:
– States (e.g. Australia, Germany, Austria, Nigeria)
– Local governments (e.g. Belgium, Spain, also Germany, Austria,
Nigeria)
• Degree of allocation varies (and changes over time):
– Total redistribution - Australia
– Sharing - e.g. Germany (ca. 50 %), Spain (ca. 1/3), Austria (ca. ¼),
Nigeria (65 %), Argentina (ca. 40 %)
– In some federations national VAT is not shared at all (e.g. Switzerland,
Canada’s federal VAT, Russia since 2001)
Decentralized VAT: revenue allocation
formulas
• Types of allocation:
– indirect (through grants, general transfers, e.g. Argentina) and direct
(earmarking)
– vertical and horizontal (or both)
•
Allocation keys established through:
– prescribed percentages (e.g. Nigeria)
– formulae (e.g. Australia)
• Allocation bases:
–
–
–
–
consumption (Spain, Japan, Korea, Isle of Man in UK, proposed for EU)
transaction or “derivation” basis (China)
population (Germany), School-aged children (Belgium)
population + “relativity” (level of development, cost of providing
services, fiscal capacity) (Australia)
– poverty (Morocco)
So how do regional VATs work?
REGIONAL VATS
Central issues in
sub-national VAT design
• Assure that regional VAT:
–
–
–
–
–
–
–
–
respects fiscal autonomy of regions/states and accrues to them
preserves VAT chain
does not impede intra-state trade
does not distort production and falls on consumption
does not distort locational decision (competition)
exhibits compliance symmetry
is simple and not costly to comply with and administer
provides proper incentives for VAT enforcement/collection by tax administration
• Not a big challenge in “no border adjustment” setting if:
– intra-state trade balance identical, and
– full harmonization of base and rate in place
• Unfortunately, this does not happen in practice; and… harmonization goes
against the objective of fiscal autonomy
Destination vs. origin basis
• Destination basis:
– superior economically but quite difficult to enforce
– implemented through:
• immediate zero-rating of sales and deferred payment on acquisition (e.g. EU,
Canada)
• deferred zero-rating and advance payment on intra-state aqusition (e.g. EEU)
– does not immediately solve cross-border shopping (most of B2C supplies
taxed on origin basis)
• Origin basis:
– easier administratively but distortive and not equitable revenue-wise
– distortions tackled through:
• lower/harmonized rates on intra-state transactions (imperfect!)
• clearing house (concept not yet applied in practice, surrogate used by EU for MOSS)
• deductions/refunds in country of origin (partially in EU, proposed as default
measure in 1998)
– revenue protected through numerous carve-outs and shift to destination
basis for B2C transactions (widespread in EU)
Different types of regional VATs
• Canada – HST, piggybacked (dual VATs), harmonized, destination
basis (zero-rating in Quebec)
• Brazil – origin based ICMS, some harmonization with lower and
harmonized rates on intra-state transactions
• India – origin based state taxes (VAT-like); inter-state trade taxed
with federal VAT
• Economic blocs (no fiscal borders):
– EU (single market) – separate VATs, fairly harmonized,
destination/origin based, deferred payment, some elements of
revenue sharing
– EEU (common market) – coordinated, destination/origin based, zerorating upon VAT payment in country of acquisition
• WEAMU – fairly harmonized VAT, plans to do away with borders
VAT in Brazil - overview
• A pioneer in the VAT world!
• Two types of VAT (non-cascading sales tax):
– Federal: Tax on manufactured production (IPI)
• tax (excise) on select goods only,
• significant limitation to deduction of credits
• rates varying by category of goods (0-330%)
– State: Tax on circulation of goods and services (ICMS)
• distinct from IPI, with overlapping base, no piggybacking
• Some degree of harmonization, independent administration
• limited in scope: goods and select services (cross-border, inter-state
and inter-municipal transportation and communication)
• dual rates: intrastate and interstate (rates set by federation)
• origin principle, no clearing used (equalization in “importing” state)
• Plus municipal tax on services (ISS) – gross receipt,
cascading
VAT in Brazil - issues
• No comprehensive, broad-based tax
• Complex structure – three different taxes, little
harmonization (even more so in practice, e.g.
enforcement of “tax substitution” scheme)
• High compliance and administrative costs
• Pervasive distortions (cascading, tax exporting)
• Inter-state tax competition
• Revenue productivity undermined
• Development objectives not met
VAT in India -overview
• No genuine VAT due to strict separation of taxing power:
–
–
–
–
Union: production of goods, most services
States: sales of goods, and few specific services
Interstate trade: Central Sales Tax in origin state
In practice: overlapping base for goods and cascading
• Since ‘86 central “VAT” – Mod VAT CenVAT:
– Replaced Union Excise Duty
– Limited crediting mechanism (ModVAT), widened under CenVAT
– Deferred deduction of input tax for capital goods, no deduction of
other (state) taxes paid on inputs, beyond manufacturing level
– Applied only at manufacturing level, widened over time
– Numerous rates, different for goods and services
• In 2005 central VAT supplemented with state VAT (pre-retail level)
• Overall design: CenVAT, state VAT, plus CST
VAT in India – planned reform (2016)
• Dual VAT for all goods and services, replacing:
– Central GST: current CenVAT (excise duty and service tax),
– State GST: current VAT, entry tax, luxury tax and entertainment
tax
– Integrated GST: on interstate supply of goods and services
•
•
•
•
Full crediting, no cross-crediting
CGST and IGST collected by central tax administration
SGST collected by state tax administration
Interstate VAT charged in origin state and credited in
destination state; revenue apportioned afterwards
• Compensation for states losing revenue foreseen for 5 yrs.
VAT in Canada (1)
• Dual VAT:
– Federal: GST at 5% applied throughout the country
– Provincial: HST at 8-10% in most provinces, administered by federal tax
administration
– Some exceptions:
• Quebec: GST+QST, both administered by Quebec tax administration
• 3 provinces: GST+RST
• Alberta: only GST
• Design (in a nutshell):
– Both GST & HST on destination basis
– HST harmonized, largely piggybacked on GST but not fully, e.g.:
• some limitation to deductions in QST
• new housing taxed differently in all provinces
• Books (taxed under GST), zero-rated under HST
– Choice of HST rates left to provinces’ discretion
VAT in Canada (2)
• Important: Dual VAT administered by federal administration
(except Quebec)
• Inter-province trade and services taxed in province of origin
basis, but credit taken in province of destination
• Excess credits generated by HST may be offset against GST
• No zero-rating (as in past); with QST as an exception
• In practice HST an integrated national tax
• Revenue shared among provinces:
– Revenue from GST & HST collected by federation is pooled
– Provinces’ shares in GST base are calculated on
destination/consumption basis
– This base is used for HST redistribution (by applying effective
HST rate to the share of GST base)
How does the VAT work in the EU?
VAT IN THE EUROPEAN UNION
A Brief History of VAT in EU (1)
• 1962 – Neumark Report recommends VAT (with eventual
adoption of origin principle for intra-EU trade)
• 1970 – Introduction of VAT (First and Second Directive ‘67)
–
–
–
–
–
Applied in all member states; a prerequisite to EEC/EU’s membership
Replacement of various gross sales taxes
Objective: improve internal market by ‘de-taxing’ exports
VAT not harmonized; early stage of coordination
VATs differed significantly; countries had much leeway
• 1970 – VAT to be part of EEC/EU’s “own resources”
– 0.3 % of uniform VAT base (with caps and reduced call-up rates, e.g.
Austria, Germany, Netherlands, Sweden)
A Brief History of VAT in EU (2)
• 1977 – VAT “harmonization” (Sixth Directive ‘77)
–
–
–
–
Objective: adopting broadly identical VAT
Minimum rate: 15 percent, reduced rates on select items
Destination principle and border adjustments kept
Cross-border refund system introduced (Eighth Directive ‘79)
• Mid ‘80s – towards a single market, proposal to
remove (costly) fiscal barriers
– Origin principle proposed – to lower the cost of cross-border
transactions
– Clearing system for reallocation of VAT (otherwise Germany and
Benelux the winners) – not accepted
A Brief History of VAT in EU (3)
• 1993 – transitional system adopted:
– Fiscal borders removed, no tax controls
– Two principles in place:
• Destination principle for B2B transactions,
• Origin principle for final consumers (B2C) but:
– Distance sales, tax exempt legal entities (e.g. banks) and new means of transport
– VIES and Fiscalis to reinforce cooperation and functioning of VAT
• 1996 onwards – towards “definitive” system
– Transitional system meant to apply until 1996
– No progress towards origin based VAT (though further proposals made,
e.g. system of deduction in the country of origin proposed in 1998)
– Focus on improvement of the transitional VAT - numerous policy
documents and proposals made, various changes introduced
Summary of VAT developments
Further harmonization
Extension of destination principle
•Base
•Rate
•Administrative procedures
• Place of supply rules
• Special schemes
• Exchange of information
Improvements to enforcement
• Mutual assistance/joint audits
• Capacity building
EU VAT – current structure
•
VATs levied by member states (no effective EU government):
–
•
•
•
Obligatory, with harmonized structure (to large extent), coordinated
implementation
Broad-based consumption tax
Operated largely on destination basis:
–
–
•
•
•
•
28 VAT national regimes, 28 distinct tax administrations
intra-community trade (B2B) relying on deferred payment (reverse charging)
cross-border supplies to consumers (B2C) relying on “forced” registration (deemed place of supply)
No clearing mechanism for origin based taxation (most B2C supplies);
No VAT transfers/remittance between states (exception: MOSS scheme since 2015)
Catering well to single market idea, not perfectly though;
High complexity due to:
–
–
numerous schemes and exceptions
need to register (or appoint tax representative) in many states
Critical issues in EU’s VAT
• Proper functioning of regional VATs in Europe
depends much on:
– degree of harmonization
– rules on place of supply
– implementation of destination principle
– keeping complexity in check (compliance cost)
– efficiency of tax administrations
• Trade off between above objectives
VAT harmonization in EU (1)
• Single policy - EU legislations (e.g. directives) transposed to national
tax systems; reinforced by European Court of Justice
• Full harmonization not yet achieved:
– numerous derogations, e.g. territorial , national, including parking
rates, ad hoc derogations
– discretion in choice of certain design features, e.g. some exemptions
and thresholds (registration, distance sales, legal entities)
– optional solutions, e.g. place of supply (effective use and enjoyment),
special regimes (e.g. flat schemes)
– some leeway in VAT administration (e.g. registration, guarantees,
filing, refunds, etc.)
• VAT rates not harmonized, only:
– minimum standard rate of 15 percent (maximum is a political
agreement)
– number of reduced rates (reduced and super reduced)
VAT harmonization in EU (2)
• Lack of full harmonization impacts cross-border trade (hence
functioning of single market) and revenues capacity of member
states:
– higher compliance costs, even if borders do not exist
– cross-border shopping: exploitation of rate differences by:
• final consumers, including non VAT entities
• businesses – location for distance sales
• Hence, adjustments to place of supply to alter origin base (by
default applicable to B2C), e.g.:
–
–
–
–
–
Distance sales of goods,
Means of transportation,
Supplies of gas, electricity, telecommunication, etc.
Digital services
Transportation services
Place of supply
• A critical concept of VAT as it determines where supplies are taxed
and which state gets VAT (cross-border trade or not)
• In line with destination principle and nature of VAT it should be
where goods/services are consumed in economic sense (directly or
indirectly)
• A tricky concept to define in practice, especially in case of services,
(rendering, enjoyment, establishment of supplier or consumer),
e.g.:
– advertisement, entertainment, renovation, accounting, legal
– assembly or installation (service or goods)
– triangular supplies of goods
• In general place of supply deemed to be where:
– customer is established (B2B), or
– supplier is established (B2C)
• Numerous exceptions exist
Intra-community acquisition of goods
• Conditions:
– supplier and buyer are VAT registered businesses
– traded goods are transported across the border
– it’s irrelevant:
• where supplier and buyer are established, or
• if they are different businesses/taxpayers
• Place of taxation:
– [standard] state of buyer’s VAT registration
– [triangular] state of final arrival of goods
• Exceptions - there is no ICA in case of (e.g.):
• distance selling above threshold
• acquisition of gas, heat, electricity
• installation and assembly
– In such case – registration in the state of acquisition required
Supply of goods
• In general (B2C) – where supplier is established
• Specific rules:
– where goods are located (immovable property, assembly/installation of goods)
– where customer is located (distance sales above the threshold, gas, electricity,
etc.)
– where passenger vessel starts its journey (goods sold to passengers)
• Such cross-border transactions:
– require foreign company to register in the state of supply/taxation to charge
local VAT
– ICA can still be part of the transaction chain (e.g assembly/installation)
• This increases cost of compliance but in line with implementation of
destination principle
Supply of services (general)
• No concept of importation or intra-community acquisition
of services
• EU’s treatment:
– not different from other countries, or
– before 1993 as physical/fiscal borders irrelevant for services
• Services taxed in the state/country where place of supply
• For cross-border services reverse charge mechanism used
• Place of supply depends on:
– status of customer (B2B or B2C), and
– nature of service (identified by EU due growing trade)
• To ensure that VAT receipts better accrue to state of
consumption several exceptions introduced over time
Supply of services (specific)
• For B2C services:
–
–
–
–
Transport of goods (non-ICA): where service performed
Repair/valuation of movable property: where service performed
Car rental (long term): where customer resides
Telecommunication, broadcasting, digital services: where customer
resides
• For B2C and B2B:
– passenger transport: according to distance covered
– services related to immovable property (e.g. hotel accommodation,
construction): where the property is
– Admission to cultural, sporting, entertainment etc. events: where the
event take place
– Restaurant and catering services: where services performed
– Car rental (short term): where car is put at customer’s disposal
Implementation of destination principle
• Deferred payment (B2B)
Simple workings, similar to import/export but with no border
adjustment (Germany-France intra-community supply example):
• Supplier charges zero-rate and issues VAT invoice with buyer’s VAT
number (validated through VIES); then claims input VAT in Germany
(deduction or refund);
• Goods cross physical border with no tax control – no tax is paid at the
entry to France
• Buyer accounts for French VAT (at rate applicable in France) when
goods are used in his production or sales - input tax, i.e. tax on intraEU acquisition, becomes a credit claimed in one return
• Taxpayer’s registration in state of supply (mostly B2C)
– French company registers in Germany to supply certain goods,
e.g. distance sales, and services, e.g. telecommunication
Challenges in VAT administration
• VATs handled by national tax administrations,
thus different:
– traditions, enforcement tools, and overall capacity
• Ease of interpretation and enforcement:
– complexity of cross-border VATs
– quality of national legislation (transposition of EU law
and ECJ’s rulings)
– direct application of EU’s directives
– interactions of “not that uniform” national VATs
• Exploitation of weaknesses in VAT design - fraud
Common fraud in cross-border VAT
• Standard evasion involves:
– illegitimate refunds,
– no accounting for VAT while charging it to customer and
– no remittance of charged VAT, i.e. missing trader scheme disappearance of taxpayer before VAT is remitted (phony bankruptcies,
bogus companies)
• Cross-border fraud:
– exploits the weakest element of VAT design: deferred payment
– Two types:
• acquisition fraud (missing trader scheme – first link in supply chain)
• carousel fraud (missing trader + refunds – first and last link)
– Commonly involves small goods of high value (e.g. mobile phones),
also services (e.g. greenhouse gas emission allowances trade)
• Tackled commonly through reverse charge mechanism and better
enforcement/administrative cooperation
Response to problems
in VAT administration
• VAT information exchange system (VIES)
• Mutual assistance, joint actions (audits)
• Improved IT systems and communication
between tax administrations
• Fiscalis program – cooperation of tax
administrations (exchange of practices,
networking, training)
• Continuous improvements/changes to VAT
system
What are the possibilities for improvement of VAT design in federations?
ALTERNATIVE VAT DESIGN
So far experience points to the
following solutions:
• Joint VAT:
– Federal but decentralized VAT with revenue sharing (most
federal sates)
• Separate VATs:
– Origin basis with no clearing mechanism and offsetting (India)
– Origin basis with no clearing mechanism but some form of
equalization (Brazil)
– Zero-rating and differed payment (as in EU, Quebec)
– Deferred zero-rating and advance payment (EEU)
• Dual VAT:
– Origin basis with crediting against federal tax (dual harmonized
VAT, as in Canada)
Alternative solutions
to sub-national VAT
• Origin basis with clearing house mechanism
(as proposed for EU)
• Compensating VAT: CVAT or “little boat” (as
proposed by Varsano)
• Viable integrated VAT: VIVAT (as proposed by
Keen and Smith)
Compensating VAT (CVAT)
• Requires dual VAT – federal and state level, with CVAT being an
addition to federal VAT
• Preserves destination base without break in VAT chain:
– zero-rating under state VAT in “exporting” state (refunds) and anew
standard taxation in “importing” state, with simultaneous
– add-on of CVAT to standard federal VAT in “exporting” state (recovered
in “importing” state)
• Tax is carried between states in CVAT; reallocation required
• Under such scheme CVAT rate at the average rate of state taxes (no
room for competition and scope for fraud limited)
• Compliance strategy not assured – need to distinguish between
intra and inter state transactions; plus traders and non-traders
• CVAT does not solve problem of cross-border shopping
Viable Integrated VAT (VIVAT)
• Integrated, i.e. single VAT with rate differentiation for:
– intermediate trade (B2B) – single across federation
– final sales (B2C) – set by states
• Intermediate rate ideally lower than final rate (otherwise
refunds needed at retail stage and VAT chain weakened)
• No need to distinguish between intra and inter state trade
(compliance symmetry)
• Still need to distinguish between B2B and B2C (compliance
asymmetry)
• Preserves destination principle and provincial autonomy
• Clearing mechanism needed; not a challenge if VAT
administered by a single agency
A numerical example
Keen (2000), p. 8
Let’s compare…
Rate autonomy
Collection incentives
Separate
VATs
Dual VATs
Joint VAT
CVAT
VIVAT
Yes
Yes
Possible
Some
Some
Strong
Strong
Good
Unknown
Unknown
Compliance symmetry
No
No
Yes
No
Yes
Need to identify destination state
Yes
No
No
Yes
Low
Moderate
Higher?
Need to distinguish types of purchasers*
No
No
Depends on
system
No
No
Yes
Yes
Credit tracking
Yes
No
No
No
Yes
Excess credits
Some
Few
No
Some
Yes
Administrative capacity
High
Less
Lower
Moderate
High
Central administration
No
Some needed
Probable**
Probably
Probably
Need for single administration
No
Preferable
Yes
No
No
Need for central state cooperation
No
Yes
Yes
High
Independent
Independent
Formula
Administrative cost
Revenue distribution
Need for clearing of some credits
Potential for interstate evasion
Cross-border shopping a problem
* Other than exempt
** Probable but not necessary
Source: R. Bird (2013), adapted
High
No
No
No
Yes
Essentially
independent
Yes
High
Restricted
No
Restricted
Restricted
Yes
Yes
No
Yes
Yes
Yes
Yes
For further reading…
•
•
•
•
•
•
•
•
Bird R. (2013), Decentralizing Value Added Taxes in Federations and Common Markets, Bulletin for
International Taxation, IBFD, pp. 655-72
Bizioli G and C. Sacchetto, eds. (2011), Tax Aspects of Fiscal Federalism. A Comparative Analysis,
IBFD, Amsterdam
Brederode van, R. and P. Gendron (2013), The Taxation of Cross-Border Interstate Sales in Federal or
Common Markets, World Journal of VAT/GST, Law, 2:1, pp. 1-23
Cottarelli C. and M. Guerguil, eds. (2015), Designing a European Fiscal Union. Lessons from the
experience of fiscal federations, Routledge, New York
Keen M. (2000), VIVAT, CVAT and All That: New Forms of Value-Added Tax for Federal Systems, IMF
Working Paper, WP/00/83,
Perry V. (2012), International Experience in Implementing VATs in Federal Jurisdictions: A Summary,
Tax Law Review, 63:623, pp. 623-38
Purohit M. (2002), Harmonizing Taxation of Interstate Trade under a Sub-National VAT – Lessons
from International Experience, VAT Monitor, pp. 169-19
Varsano R. (2000), Sub-National Taxation and Treatment of Inter-State Trade in Brazil: Problems and
Proposed Solutions, in: S. Burki and G. Peary (eds.), Decentralization and Accountibility of the Public
Sector, World Bank, Washington
Thank you
aswistak@imf.org