0% found this document useful (0 votes)

60 views

Ess Survey 13 Nov 17

This document is a 2017 survey by KPMG International on the VAT/GST treatment of cross-border services. It contains a foreword, an analysis of challenges in the digital economy, interpretation of survey findings, key findings, and summaries of VAT/GST rules in over 50 countries.

Uploaded by

Ravi

We take content rights seriously. If you suspect this is your content, claim it here.

Available Formats

Download as PDF, TXT or read online on Scribd

0% found this document useful (0 votes)

60 views

Ess Survey 13 Nov 17

Uploaded by

Ravi

We take content rights seriously. If you suspect this is your content, claim it here.

Available Formats

Download as PDF, TXT or read online on Scribd

You are on page 1/ 90

VAT/GST

treatment of
cross-border
services
2017 survey

November 2017

KPMG International

kpmg.com/indirecttax
Contents
Foreword 2
VAT/GST and the digital economy:
the untold story of global challenges 4
Interpreting the survey's findings 16
Summary of key findings 22
Global Indirect Tax Services
Andorra 28
Argentina 29
Australia 30
Austria 32
Bahamas 33
Belarus 34
Belgium 35
Brazil 36
Bulgaria 37
Canada 38
China 40
Colombia 41
Croatia 42
Cyprus 43
Czech Republic 44
Denmark 45
Egypt 46
Finland 47
France 48
Germany 49
Ghana 50
Iceland 51
India 52
Indonesia 54
Ireland 55

© 2017 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Isle of Man 56
Italy 57
Japan 58
Kenya 60
Lithuania 61
Luxembourg 62
Malaysia 63
Malta 64
Mexico 65
Netherlands 66
New Zealand 67
Norway 68
Poland 69
Portugal 70
Romania 71
Russia 72
Serbia 73
Singapore 75
Slovakia 76
Slovenia 77
South Africa 78
South Korea 80
Spain 81
Sweden 82
Switzerland and Liechtenstein 83
Tanzania 84
Thailand 85
Turkey 86
United Kingdom 87

Foreword
In the US, we recently observed the 50th anniversary of the its seeds by mail-order and its average order was quite low.
issue of how to collect tax on cross-border sales by remote You see the problem. How can a company whose average
sellers to proximate consumers. In a seminal case — known sale is only worth a few dollars be expected to subject itself
as National Bellas Hess — the US Supreme Court decided to the jurisdiction of a distant state — with all that jurisdiction
that states could not require remote sellers with no physical entails (notices, audits, filings, etc.)? Put simply, they can’t.
presence to collect and remit ‘use tax’ on mail-order sales. Not even with a collection cost allowance.
Twenty years later, this issue unexpectedly began shaping Never has this issue been as important or as global as it is
my own career when, in 1989 as a student, I was asked to now, for at least three reasons:
‘blindly’ select the topic for my thesis — from a hat — it
The rise of the digital economy
was “The collection of transaction based taxes on cross-
border sales by remote sellers”. I published my thesis in the From 2015 to 2020, the digital economy is projected to expand
Georgetown Law Journal in 1991, thus setting in motion the from 22.5 percent of the global economy to 25 percent and
wheels that have formed quite a bit of my career. Little did I that growth is expected to continue. It took 12 years for the
know then that these issues would still be around over yet internet to gather one billion users, but only 4 years to achieve
another 25 years later. And never did I think that the issue 3 billion users. The early users surfed the internet and sent
would actually expand in scope and significance. email. But the next 1 billion users will have grown up using the
internet for e-commerce from day one. When I ask my Alexa
As I reflect on this, what is most striking is how similar the
app to order paper towels, I do not care who the seller is and
issues are worldwide. For example, let’s consider the plight
where the seller is located!
of the small and medium enterprise. From my thesis — of
which I’ve forgotten quite a bit — I can never forget the The rise of transaction taxes
powerful impact of the 1980’s testimony on Capitol Hill by the
From 1969 to 2017, we have truly witnessed a tax policy
George W Park Seed company. The Park Seed Company sold
revolution. From eight countries in 1969 to more than 170
seeds, the perfect sort of fact pattern to grab the attention
today, transaction taxes have swept the globe (VAT/GST and
of legislators because seeds are necessary for food and
other transaction taxes with different names). Taxation of
flowers and because the buyers of seeds in the 1980s were
consumption at the transaction level has transformed the
common working people, perfect to elicit the sympathy of
tax landscape. There was a time when legislative bodies
representatives in Congress. The Park Seed Company sold

feared enacting a VAT due to political repercussions. But, business, these changes are complex, lengthy and difficult
in spite of that, over 170 countries now have, and even the to follow whether trying to determine VAT/GST obligations,
US occasionally flirts with something that is a VAT. With the assess compliance challenges, understand government data
increased emphasis on transaction taxes globally, the issues requirements or deal with disruptive business models.
we face today have become more important.
KPMG International's 2017 survey on VAT/GST and cross-
The decline of corporate tax border supplies of B2B and B2C services, involving 54
countries, provides a comprehensive global reference on
At the same time that we’ve witnessed the increased prevalence
which businesses can look to build their knowledge and
of VAT/GST, we’ve seen the rather dramatic decline of corporate
develop further insights into how best to manage indirect
income tax rates — from over 30 countries with rates of over
taxes in this complex area. But as the survey shows, we are
50 percent 30 years ago to only five countries with rates at this
still a long way from having a clear and consistent framework
level today, and a current environment where the US rate of 35
for taxation in the digital economy.
percent is out of line and on the high side. In Europe alone, we
see rates of 12.5 percent and 11 percent as examples.
The truth is that we saw radical tax reform across the globe in
the 20th century, and the ramifications of these reforms and
the change in the global and domestic economies are now
coming to the fore.
Into this environment, the work carried out by the OECD in
terms of its International VAT/GST guidelines are welcome
and will play a significant part in shaping the regulatory and
business environment around B2B and B2C, cross border
supplies of services. But they do not arise in isolation, and
around the globe, the 'indirect tax map' is full of recent or Tim Gillis
proposed changes, many of which are, as expected, not Head of Global Indirect Tax Services
harmonized with other countries. For the multi-national KPMG International

VAT/GST and the digital

economy: the untold story of
global challenges
By Philippe Stephanny, Senior Manager, KPMG in the US and Juan Vazquez (extern)

Technological changes and improvements have created new challenges for businesses
regarding compliance with value added tax (“VAT”) laws. This article is intended as a
guide to assist businesses in understanding new VAT rules applicable to digital goods
and services, identifying when a business may have VAT obligations, and understanding
compliance requirements and other pitfalls.

Not so long ago, neither VAT, also known as goods and services Digital economy VAT 101
tax (“GST”), nor the internet existed. First, the French1 dared
As a consumption tax, VAT traditionally applies where the
to implement a new form of taxation that would spread
consumption occurs following the so-called destination
across the globe and become so popular that now more than
principle.2 In cross-border transactions involving tangible
165 jurisdictions use it as a steady source of revenue. The
personal property, this is achieved by not taxing exports
idea is simple: taxing consumption rather than income and
and imposing VAT at the port of entry in the country of
requiring domestic businesses to collect the tax on behalf of
import. Most jurisdictions currently exempt from VAT
the government on domestic sales of goods and services. But
the importation of low-value goods (“LVG”) by final
then the Big Bang occurred: thanks to the internet, sellers of
consumers as the cost of administration is considered
goods and services could have immediate access to a global
greater than the eventual revenue collected from these
market, and the World Wide Web rapidly became the town
imports.3 Applying the destination principle to services and
square for the global village. Today, a company operating from
intangibles is more challenging because of the difficulty
a garage in Palo Alto, California (or any place on the globe with
in identifying the jurisdiction of consumption as well as
a decent internet connection), can sell its digitized products to
the potential compliance obligations that could confront
millions of customers around the globe without a single sales
a multijurisdictional seller. As a rule of thumb, most
representative setting foot in a foreign country.
jurisdictions have traditionally applied the following rules to
The growing digital economy exposed the logical cracks sales of services and intangibles generally:
in the VAT rules applicable to brick and mortar businesses,
—— For business-to-business (“B2B”) transactions, VAT is due
and countries became concerned about a loss in revenues
in the country of the customer
because the existing VAT rules did not tax consumption of
digital products in the country of consumption. As countries —— For business-to-consumer (“B2C”) transactions, VAT is
began to modify their VAT laws to face these new challenges, due in the country of the vendor
e-commerce providers became global tax citizens, dragging
These rules were developed when most VAT systems were
traditional businesses into the global tax net with them.
originally implemented and consumers acquired goods and
This article is intended as a guide to assist businesses in
services primarily from domestic vendors. At that time, the
understanding the new VAT rules applicable to digital goods
places of sale and consumption were generally located within
and services, identifying when the business may have VAT
a single jurisdiction. For B2C transactions, the location of
obligations, and understanding compliance requirements and
the vendor seemed to be a reasonable proxy for the place of
other pitfalls the rules may entail.

*
hilippe Stephanny is a senior manager in the State and Local Taxation (“SALT”) group of Washington National Tax (“WNT”). Juan Vazquez is an
P
extern with the WNT SALT group.
1
Ebrill, Keen, Bodin & Summers, The Modern VAT 4 (IMF 2001).
2
For a discussion of why a destination-based taxation is preferred, see Keen & Hellerstein, Interjurisdictional Issues in the Design of a VAT, 63 Tax
Law Rev. 359, 365-66 (2010). See also Ebrill, The Modern VAT, at 177–84.
3
See Laura Mattes, VAT Aspects of Cross-Border Transactions in the BEPS Era, IBFD Int’l VAT Monitor, May/June 2016, at 176.

consumption since the impact of not imposing VAT on cross- the Bahamas, Belarus, Colombia, the 28 Member States of the
border services was minimal, as the volume of transactions EU, the six member states of the Gulf Cooperation Council,
was not significant. The same reasoning applied to the Ghana, Iceland, India, Japan , Kenya, New Zealand, Norway,
exemption of B2C imports of LVG. Serbia, South Africa, South Korea, Switzerland, Taiwan, and
Tanzania. It is expected that the number of countries adapting
The “digital revolution” disrupted traditional business models,
their VAT/GST laws to the challenges of the digital economy will
and the VAT revenue foregone by not taxing cross-border sales
only grow in the upcoming years.
of digital goods and services generated serious concerns for
many tax authorities worldwide. In New Zealand, for example,
a VAT leakage of 180 million New Zealand dollars (NZD)
Identifying foreign VAT obligations in cross-
(114 million US dollars (USD)) per year has been reported as
border sales of services and intangibles
a result of cross-border services, intangibles, and goods.4 Companies involved in cross-border sales of services and
While the European Union (the “EU”) partially addressed intangibles must carefully go through an iterative process
these challenges in 2003,5 it was not until late 2015 that the to determine their potential foreign VAT obligations. For
Organisation of Economic Cooperation and Development simplification purposes, we will refer to these sales as sales
(the “OECD”) published its updated International VAT/GST of digital services because most new rules are aimed at these
Guidelines6 (the “Guidelines”), which were endorsed by more types of products and services. Examples of these digital
than 100 jurisdictions. The Guidelines endorse the destination services include downloaded or streamed books, music, and
principle as the international norm and recommend that B2B movies, online games, software, and telecommunications
and B2C transactions be taxed in the country in which the services. However, the scope of these services may be even
customer is established, except for B2C “on-the-spot” services broader, as discussed below.
(e.g., personal services, accommodations, restaurants, etc.), The order of the following steps may vary depending on the
which should be taxed where the service is rendered. Also, information available to a company. While some might suggest
the Guidelines recommend that services related to immovable reviewing the type of services sold, we suggest first identifying
property should be taxed where the property is located. The countries where sales are made and maintaining a good
Guidelines further recommend that for B2C services, the understanding of the business supply chain. This approach
nonresident vendor should register for and charge VAT in the allows companies to quickly “scope out” a large number of
country in which the consumer is located. For B2B services, jurisdictions. For instance, if a company makes sales only to
the Guidelines suggest that the business recipient should self- countries in Latin America, the underlying VAT risk will (for now)
assess VAT through a reverse charge or similar mechanism. likely be low, and the company would have only to monitor
The adoption of the Guidelines seems to have jump-started developments in the region (e.g., Colombia). On the opposite
the process of adapting VAT/GST rules to the challenges of the end of the spectrum, when making sales to EU countries, the
digital economy as a number of countries/jurisdictions have, VAT risk will likely be higher, and a company will have to carefully
or are in the process of, implementing new rules that largely asses the likely VAT obligations arising from its transactions.
conform to the OECD Guidelines, including Australia, Albania,

4
New Zealand Inland Revenue, GST: Cross-border services, intangibles and goods. A government discussion paper (2015).
5
Before 2015, the EU required non-EU businesses to register for and charge VAT in the Member State of consumption on sales of electronic supplied
services to EU consumers. However, these rules were not applicable to EU businesses making identical sales. In 2015, the EU harmonized the VAT
treatment of these sales, requiring all B2C vendors of telecommunications, broadcasting, and electronic supplied services to register for and charge
VAT in the Member State of consumption. See e.g., Philippe Stephanny, Upcoming 2015 Changes in EU Sourcing Rules For Electronic Supplies,
Broadcasting and Telecommunications Services, 23 BNA Daily Tax Rep. J-1 (4 Feb. 2014).
6
OECD, International VAT/GST Guidelines, available at http://www.oecd.org/tax/consumption/international-vat-gst-guidelines.pdf.

Step 1: Step 2:
Identifying countries where Determining the person liable to comply with
sales are made foreign VAT laws

The first step for any company involved in digital sales is to Once a business has identified the countries in which it
establish a list of countries in which sales are made. This makes sales of digital services, it should review its supply
list will constitute the basis for further analysis, and should chain and determine whether the company itself or a
be reviewed and updated regularly as new jurisdictions third party is liable for compliance with the foreign VAT
introduce special rules for digital sales. requirements. Many countries have enacted special rules
for sales involving intermediaries, especially electronic
From the list of foreign jurisdictions, the company should then
marketplaces (e-marketplaces). Under these rules, sales
categorize the jurisdictions into those that have implemented
via an e-marketplace are deemed to be carried out by the
special rules for digital sales, those that will implement
e-marketplace and not by each individual vendor, thereby
these rules in the near term, and those that are considering
shifting the VAT liability (and compliance obligations) from the
changes in the longer term. This segregation will help the
vendor to the e-marketplace.
company focus on those transactions that have the most
immediacy. While this approach allows an identification of Approaches to the taxation of the intermediaries may vary
most jurisdictions in which a foreign VAT obligation for sales among jurisdictions depending on contractual terms. For
of digital services may arise, such an obligation may also instance, the EU and Australia have rules that deem an
arise in other jurisdictions under current VAT/GST rules not intermediary involved in “key aspects of the sale” to be
specifically aimed at digital services. In Canada, for example, the vendor. Under the EU approach, for each transaction in
under the general GST rules, a nonresident vendor that has the supply chain, each entity is deemed to have received
a permanent establishment (“PE”) in Canada is treated as a and resold the digital service itself (reseller assumption).8
resident and must in general register and collect GST for the Thus, under this assumption, an e-marketplace operator
activities carried on through that PE. Moreover, nonresidents involved in “key aspects of the sale” to the final consumers
without a PE may be required to register for GST purposes is required to account for VAT. In assessing whether a taxable
if they are considered “carrying on a business in Canada” person is involved in “key aspects of the sale,” both facts
based on a 12-factor test.7 For this reason, businesses should and legal relationships need to be taken into account. The
perform a somewhat abbreviated second round verification of EU “Explanatory Notes” provide guidance and a number of
all remaining jurisdictions. examples indicative of this requirement, including owning
the online platform, controlling or influencing pricing policy,
Finally, businesses should be aware that determining
owning customer data, etc.9 The assumption can be rebutted
where sales are made for VAT/GST purposes may require
if both the facts and the contractual arrangements between
identification of customer location, which involves some
the relevant parties demonstrate that the actual individual
complexity, as we discuss below under the compliance
vendor and not the e-marketplace is rendering the service.
obligation. As a consequence, when evaluating countries
Moreover, a payment service provider that merely processes
with potential sales, businesses should first use data that is
the payment for the provision of e-services (e.g., a credit
readily available to broadly identify whether a potential foreign
card company) is not subject to the assumption in the EU.
VAT obligation exists. At a later stage, businesses should take
In contrast, under Australian rules,10 an e-marketplace is
into consideration the complex compliance rules and verify
treated as the vendor of inbound intangible B2C sales, but
whether additional VAT liabilities exist.
this treatment does not extend to deeming the intermediary

7
See GST/HST Policy Statement P-051R2.
8
Council Implementing Regulation (EU) No 1042/2013 of 7 October 2013 amending Implementing Regulation (EU) No 282/2011 as regards the place
of supply of services [2013] OJ L284/1 (Council Regulation 1042/2013), art 9a. See also Teck Chin Lim, Introducing the ‘Netflix Tax’ in Singapore: The
antipodean and European approaches, 101 Taxation Today 12, 19-20 (2016).
9
European Commission, Explanatory notes on the EU VAT changes to the place of supply of telecommunications, broadcasting and electronic
services that enter into force in 2015, at 28 (3 Apr. 2014), available at http://ec.europa.eu/taxation_customs/sites/taxation/files/resources/documents/
taxation/vat/how_vat_works/telecom/explanat ory_notes_2015_en.pdf.
10
A New Tax System (Goods and Services Tax) Act 1999 (Australia) (AGSTA), § 84-55(1).

to have acquired the digital content. Furthermore, under Some jurisdictions adopt a relatively narrow definition of digital
Australian rules, the services provided by the operator of services. In South Korea, for example, the rules on digital
the e-marketplace, such as agency or facilitation services, services apply only to limited “content-oriented” transactions
are treated separately in accordance with the business such as games, video files, electronic documents, software,
agreements.11 Similarly, in New Zealand, nonresident and similar items processed by optical or electronic means and
operators of e-marketplaces (but nonresident operators) are their upgrade.15 The definition of digital services in the EU16 is
by default responsible to account for GST on remote service broader. “Electronic supplied services” are defined as services
supplies made to New Zealand customers subject to similar delivered over the internet or an electronic network that (1) are
exceptions applicable in the case of Australia.12 essentially automated, (2) involve minimal human intervention;
and (3) are impossible to ensure in the absence of information
Finally, businesses should take into consideration that
technology. The EU legislation provides a long, non-exhaustive
certain jurisdictions may have implemented joint and several
list of positive and negative examples of digital services. The
liability for vendors and e-marketplaces, which may drag
positive examples17 include, among other items, five broad
them both into the VAT net.
categories of indicative e-services (i.e., website/web‑hosting,
software, images, text and database services, media content,
and distance teaching). The negative examples18 include
Step 3: professional services provided over e-mail, advertising services
What is deemed to be a digital service? in newspapers, posters and television, distance learning
involving purely correspondence, etc. The EU rules also apply
If the company determines that it may be required to comply to telecommunications and broadcasting services.
with foreign VAT rules, it should then analyze whether the
products sold fall under the definition of digital services in Other jurisdictions take a less specific approach and more
the countries in which sales are made. The scope of services closely follow the OECD Guidelines. Australia, for example,
falling under these new rules varies greatly. does not attempt to define a specific sub-category of digital
services, but rather provides that all sales of services and
As always, the devil is in the details, and what is a taxable intangibles made to Australian consumers are prima facie
transaction in one jurisdiction may not be in others. subject to GST.19 Therefore, while primarily aiming at digital
Businesses must, therefore, analyze in depth the statutes services, the Australian rules capture more traditional
and regulations of the country in which the foreign services such as consulting, advertising, and the like. The
customer is located to be certain of the application of the European Commission in a proposal published in December
VAT e-commerce rules to their business transactions. For 2016 suggested adopting a similar approach to Australia and
example, unlike most jurisdictions with digital service rules, New Zealand by considering that all B2C services should
South Africa currently does not include the sale of software be taxed where the consumer is located, unless a specific
in the definition of digital services.13 However, in one of its exception applies.20
latest budgets, South Africa stated that it would review
the list of e-services and will likely include software and
cloud-computing.14

11
Discussion paper on issues concerning electronic distribution platforms (EDPs), TDP 2016/1, available at law.ato.gov.au.
12
Goods and Services Tax Act 1985 (New Zealand) (NZGSA), § 60C.
13
See South African Revenue Service, VAT Registration Guide for Foreign Suppliers of Electronic Services; Value-Added Tax Act (89/1991): Regulations
Prescribing Services for the purpose of the definition of “Electronic Services”, available at www.sars.gov.za.
14
South Africa's 2015 Budget, released on February 25, 2015, available at http://www.treasury.gov.za/documents/national%20budget/2015/.
Dong Suk (Daniel) Kang, KPMG Korea, South Korea: New VAT Registration for Overseas Electronic Service Providers (2015), available at https://
15

home.kpmg.com/content/dam/kpmg/pdf/2015/07/tnf-korea-july6-2015.pdf.
Council Regulation (EC) No 1777/2005 of 17 October 2005 laying down implementing measures for Directive 77/388/EEC on the common system
16

of value added tax [2005] JO L288/1 (Council Regulation 1777/2005), art. 11(1).
17
Council Regulation 1777/2005, art 11(2)(f); see also VAT Directive, annex II.
18
Council Regulation 1777/2005, art 12.
19
AGSTA, § 38-190(3).
20
European Commission, Modernizing VAT for cross-border B2C e-commerce, COM (2016) 757 final 2016/0370 (CNS) (12 Dec. 2016).

Identifying the taxability of a service may not be sufficient. the GST registration numbers to identify whether a customer
Certain jurisdictions may apply a reduced VAT rate to certain is a business, but both countries also consider that it is up to
products (e.g., e-books) or even consider that transactions the customer to provide accurate information on its status to
are VAT exempt if certain conditions are met (e.g., education the nonresident vendor and impose penalties to customers
or gambling). The taxation of bundled sales (e.g., tangible providing false information to avoid GST.24
property in combination with digital services) may create
Japan, which does not currently use a VAT identification
additional challenges to clearly determine the applicable VAT
numbering system, presents a particular challenge as the
treatment.
classification of B2B and B2C is based on the underlying
nature of the transaction. According to the Japanese rules,25
if a service can be used by private consumers, then the
Step 4: transaction qualifies as B2C sale even though the sale is to
Determining the type of customer a Japanese business (e.g., sales of e-books to Japanese
business customers). This means that, rather than identifying
Once a company identifies a transaction as being within an individual customer’s identity using VAT registration
the scope of digital services rules, it must then determine information, the distinction between B2B and B2C is made
the status of the foreign customer “on the other side of the by identifying whether a service itself, in light of its contents
counter,” as, generally speaking, there are different rules and and contract, is usually provided for business customers
implications for B2B and B2C transactions. or for final consumers. The Japanese law defines B2B
While it sounds straightforward, properly categorizing the transactions as digital services that are normally limited to
customer is, unfortunately, not necessarily simple. First, businesses with respect to the nature, terms, etc., of the
countries differ significantly in how they define a “business” services provided. Examples of services that are normally
and a “final consumer.” In general, most jurisdictions (e.g., limited to businesses with respect to their “nature” include
EU, Australia, and New Zealand) consider a final consumer to distribution of advertisements via the internet, intermediation
be a private individual not registered for VAT purposes. This in online sales of games and applications, and online hotel
category may also include other non-VAT registered persons and restaurant booking fees from hotel and restaurant
such as public bodies (e.g., India and the EU) or nonprofit owners. Services normally limited to businesses in view
organizations (e.g., EU). of their “terms” include, for instance, the provision of
electronic services such as cloud services that are individually
In practice, vendors are generally required to identify the negotiated between parties and are obviously intended for
status and location of their customers on a transaction-by- business use by the party receiving the services.26
transaction basis based on information collected through
their ordinary business processes. Under EU rules,21 for In most jurisdictions, a VAT liability for the nonresident
example, the primary evidence required to identify the status vendor is triggered only in B2C transactions—in B2B
of an EU-based business customer is the VAT identification transactions, the purchaser will usually account for VAT
number verifiable through the EU Commission’s portal,22 under the reverse charge mechanism— some jurisdictions
but alternative evidence (e.g., letter from tax authority, tax will trigger a nonresident VAT liability for both B2B and
reference number, and company registration documents) B2C transactions (e.g., South Africa). In addition, even in
may be acceptable.23 Australia and New Zealand also rely on jurisdictions where the VAT liability for B2B transactions is

21
ouncil Implementing Regulation (EU) No 282/2011 of 15 March 2011 laying down implementing measures for Directive 2006/112/EC on the
C
common system of value added tax [2011] OJ L77/1 (Council Regulation 282/2011), art. 18.
22
Council Regulation 282/2011, art. 18(1)(a).
23
Council Regulation 282/2011, arts. 18(1)(b), 3(b).
24
Taxation Administration Act 1953 (Australia), § 284-75(4); Goods and Services Tax Act 1985 (New Zealand) (NZGSTA), § 8B(5).
25
See JNTA, Revision of Consumption Taxation on Cross-border Supplies of Services (2015), available at https://www.nta.go.jp/foreign_language/
consumption_tax/cross-kokugai-en.pdf
26
Id.

shifted to the business customer, the transaction may be registration threshold applicable to domestic vendors is not
subject to a VAT withholding mechanism (e.g., Russia).27 applicable to foreign vendors. In other words, vendors from
Under a withholding system, the sales price is considered jurisdictions other than the country of consumption are under
VAT inclusive, and the business customer withholds the all circumstances required to register for VAT with respect to
VAT on behalf of the government, thus effectively reducing digital sales made to final consumers established or resident
the consideration received by the nonresident vendor. elsewhere in the EU.
This mechanism may also be applied to B2C transactions.
Some Member States implemented unilateral measures to
Colombia, for instance, is considering introduction of a VAT
relieve the compliance burden placed on small businesses
withholding scheme for B2C transactions that would require
(e.g. UK).32 To alleviate the compliance burden, the European
financial institutions through which purchases are made to
Commission released a proposal to modernize VAT rules for
withhold the required VAT.28
cross-border e-commerce as of 1 December 2016 (the “EU
VAT proposal”).33 Pursuant to the EU VAT proposal, effective
1 January 2018, EU companies with annual cross-border
Step 5: sales up to 10,000 euros (EUR) should be allowed to treat
Determining the registration threshold these sales similar to their domestic sales, and therefore deal
only with their national tax authority. Thus, instead of having
Once a company has identified that it has a potential VAT to use the VAT Mini One Stop Shop (the VAT MOSS), which
liability in a given country, it must then determine whether as discussed below allows nonresidents to register in one
its level of sales triggers a VAT registration requirement. The Member State for the collection of VAT on digital services in
approach to registration thresholds and the types of sales all the 28 EU member states, or register in each country they
that count toward its computation vary among jurisdictions. make sales, small EU sellers will be able to apply the familiar
Thresholds may vary from nil (e.g., EU, Russia), to low (e.g., VAT rules of their home country (i.e., invoicing requirements,
ZAR50,000 (USD3,413) in South Africa),29 to high (e.g., recordkeeping, etc.). However, this threshold would not
100,000 Bahamian dollars (BSD)).30 In addition, businesses apply to non-EU businesses, which would still be required
must also consider the type of sales that should be included to register for VAT purposes regardless of the volume of
in the VAT/GST threshold computation. For instance, in New their sales.
Zealand, remote services provided by a nonresident to New
Zealand GST-registered businesses do not count toward the Understanding VAT compliance obligations
registration threshold as these are not within the scope of After identifying countries in which they are required to
the tax. In Switzerland, effective 2018, worldwide sales will register, companies must understand their new compliance
be taken into consideration in computing the threshold.31 obligations.
Consequently, a single B2C sale in Switzerland may trigger
a registration obligation if sales to other jurisdictions are Registration
sufficient to exceed the threshold.
As would be expected, jurisdictions vary in their approach
In the EU context, the current regime for taxing cross- to registration between simplified registration and standard
border electronic services imposes a significant compliance registration, and in certain instances, the requirement
burden on small businesses (both EU and non-EU) since the to appoint a fiscal representative. Certain jurisdictions

27
See KPMG, Russia: VAT on the supply of e-services, effective 2017 (Sept. 19, 2016).
28
See Law 1819 of 2016, approved on December 29, 2016 (provides for structural reform of the Colombian tax system).
29
VAT Registration Guide for Foreign Suppliers of Electronic Services, available at South African Revenue Service webpage, http://www.sars.gov.za.
30
See The Government of The Bahamas Online Tax Administration; https://vat.revenue.gov.bs/Content/RegisterTaxpayer.
31
See KPMG, Switzerland: VAT provisions approved, effective beginning 2018 (Oct. 3, 2016).
32
UK HMRC released Revenue and Customs Brief 4 (2016) on January 8, 2016).
33
European Commission, Modernizing VAT for cross-border B2C e-commerce, COM (2016) 757 final 2016/0370 (CNS) (Dec. 12, 2016).

(e.g., New Zealand and Russia) have introduced a special electronic services provided in Japan, or has appointed a
“simplified” registration for nonresident vendors of digital qualified agent in Japan (e.g., a tax accountant). If a foreign
services. The vendor is liable only to report taxable sales in business does not satisfy these conditions, it is not able to
its future VAT return, but may not claim any VAT incurred on register.36
expenditures.
Filing of returns
To alleviate the burden of vendors being required to register
for VAT in each Member State in which they make a sale, A company should also be aware that the new rules for taxing
the EU introduced the VAT MOSS, a simplified registration digital services differ significantly in relation to when and how
scheme that allows EU vendors providing B2C sales of VAT/GST returns must be filed and what information they
telecommunications, broadcasting, and electronic supplied should include. The filing period may vary among countries
services (“TBE services”) to register in one Member State from monthly (e.g., South Africa), bi-monthly (e.g., Iceland),
(i.e., the “Member State of Identification”) to which it reports quarterly (e.g., New Zealand), or semi-annually (e.g., Japan)
all the sales made to the “Member States of Consumption.” in some special cases, depending on the taxpayer turnover
The Member State of Identification is responsible for and type of business conducted. The filing deadline for these
distributing taxes remitted to the Member States of returns may be extremely short. In the EU, for instance,
Consumption. However, the incomplete harmonization of businesses must file MOSS returns quarterly and submit
EU rules, combined with strict MOSS rules, prevent non-EU them within 20 days of the end of the filing period.
businesses that are already registered for VAT in one Member The short filing deadlines, combined with strict rules for not
State (e.g., because they perform taxable training services) filing timely returns, create additional pressure on businesses
from registering under MOSS for their sales of TBE services attempting to comply as they may face challenges gathering
on an EU-wide basis; such nonresident vendors must register all the required information for filing accurate returns within
in each Member State in which they make B2C sales of TBE the time allowed. To address this concern, the EU VAT
services. The EU VAT proposal would address this issue and proposal extends the filing deadline from 20 to 30 days
allow non-EU businesses with a VAT registration in an EU following the end of the quarterly tax period as a way of
member state to qualify for MOSS registration. The proposal simplifying compliance under MOSS. Many jurisdictions have
would further extend its application to all B2C sales of implemented electronic platforms to submit online returns to
services and goods. ease the filing burden. A company providing digital services
Other jurisdictions require a full VAT registration (i.e., sales should consider the specific information that the VAT/GST
and purchases must be reported), which demands more return must include, as the requirements differ greatly within
supporting information and more time than a simplified jurisdictions. These information requirements must be set-up
registration. In Switzerland, 34 for instance, once a company in the ERP system, and if applicable, the tax engine to ensure
reaches the registration threshold, all sales to Swiss full compliance with the various VAT/GST laws.
customers (not only B2C sales, but also B2B sales) become
Invoicing
subject to Swiss VAT.
A few jurisdictions also establish special invoicing
Finally, in several jurisdictions (e.g., Japan and Switzerland),35 requirements that companies should bear in mind if they are
a nonresident entity may not register directly with the tax subject to foreign VAT rules. In India and South Africa, for
authority and must appoint a local person to act as fiscal instance, nonresident vendors that are registered for VAT and
representative, which will in general be held jointly and that sell taxable digital services must issue VAT compliant
severally liable. In the case of Japan, a foreign business that invoices meeting certain requirements (e.g., provide the
wishes to register must fill in and submit a form, attaching name of the vendor, separately state the amount of tax, etc.).
evidence that it has either an office associated with B2C

34
See Swiss Federal Act on Value Added Tax and Ordinance on Value Added Tax, available at https://www.estv.admin.ch/estv/en/home.html
35
Id.; See also Japan National Tax Agency web site, Information about Consumption Tax (Guides, Notifications etc.), Basic knowledge, https://www.
nta.go.jp/foreign_language/consumption_tax/01.htm#o01.
36
Yuki Nishida, Japan Consumption Tax on Cross-Border Supplies of Services, IBFD Int’l VAT Monitor, July/Aug. 2015.

Full compliance with these requirements can be ensured only India and Belarus have implemented similar rules, but with
if the requirements are implemented in a company’s ERP some differences regarding the pieces of evidence that
system and online portal used to make sales, meaning they sellers may use to determine the customer location. In India,
may affect the customer experience. for example, a consumer will be deemed established in that
country if two conditions among seven provided by the rules
The lack of harmonization within the different jurisdictions
are satisfied (e.g., address in India, credit card issued in India,
regarding invoicing requirements further increases the
IP address in India, etc.).39 In the case of Belarus, an individual
compliance burden on businesses. This has pushed the EU
purchasing digital services is deemed to be in Belarus if at
to include in its VAT proposal a rule imposing (under the VAT
least one of the following conditions is met: (1) the individual
MOSS) the invoicing requirements of the Member State
is resident in Belarus; (2) payment is made through a bank/e-
of Identification rather than those of the Member State of
payment operator located in Belarus; (3) the individual used a
Consumption.
Belarusian IP address to purchase digital services; or (4) the
Identifying the customers’ location individual used a Belarusian telephone number to purchase
digital services.40
Several jurisdictions have introduced rules to identify in
which jurisdiction a customer is located for purposes of In practice, complying with these requirements may be
identifying the jurisdiction to which the sale is to be assigned challenging for businesses as they are likely not collecting the
for tax purposes. For example, the EU rules for B2C digital necessary pieces of evidence in advance. Finally, the use of
services include a set of rebuttable presumptions for certain different pieces of evidence may result in a customer being
transactions,37 and for all other transactions, businesses deemed to be located in two distinct taxing jurisdictions and
must determine the customer location based on two non- a business would thus have to justify why one jurisdiction
contradictory pieces of evidence such as customer billing should be preferred to the other. In particular, this can be an
address, IP address, bank details, country code of the SIM issue when a transaction involves two jurisdictions with very
card used, location of the residential fixed landline, and other different approaches. For instance, a sale will be deemed
commercially relevant information.38 As a consequence of to be taxable in Australia if it is connected with the country
these customer location requirements, many vendors of (which is interpreted broadly). That same transaction may
digital services must gather and retain two or three pieces be subject to EU VAT if, based on various pieces of evidence
of information for each customer in up to 28 Member States. collected, the consumer is deemed to be located in an
This information is not always readily available, which further EU member state. Belarus has developed an approach to
increases the compliance burden. Because of that, the EU avoiding double taxation (at least with the EU). If digital
VAT proposal suggested a gross receipts threshold of EUR services are deemed to be provided in Belarus under the
100,000 under which businesses would not be required tax laws of Belarus and simultaneously are deemed to be
to collect a minimum of two pieces of non- contradictory provided at the place of the vendor under the applicable laws
evidence. Under this new threshold, businesses can of a Member State of the EU, based on EU Directives, then
presume the customer’s location based on a single piece of the services will be sourced to the territory of the foreign
evidence. Under the current draft, the thresholds apply only state. If this occurs, the foreign entity must file a notice
to EU- established businesses. with the Belarusian tax authority informing it of the type of
electronic service and the reference to the national and the
EU legislation. Such a reference to EU legislation is unusual
as Belarus is not an EU member state.

37
Council Regulation 1042/2013, art. 24a.
38
Council Regulation 1042/2013, arts. 24b(d), 24f.
39
KPMG, India: Update on GST Reform, Inside Indirect Tax (2016).
40
KPMG, Belarus: VAT on Remote Electronic Services Effective January 1, 2017, Inside Indirect Tax (2016).

Other compliance and noncompliance items to consider may well lead to increased cooperation and information
Beyond the above issues, businesses should also consider exchange among tax authorities. The increased sharing may
what recordkeeping requirements are triggered when be accomplished by using conventional vehicles such as tax
registering for VAT/GST. Format, location, and length of information exchange agreements or perhaps special treaties
recordkeeping requirements generally vary between aimed at cooperation in VAT/GST matters. The EU is working
jurisdictions. In the EU, for instance, the registration under on improving collaboration between tax authorities within
MOSS triggers a 10- year recordkeeping obligation,41 which the EU as well as with authorities from non-EU jurisdictions
is far beyond the average recordkeeping requirements that also have a VAT system. In early June 2017, the European
throughout the EU. For that reason, the EU VAT proposal Commission announced that it had successfully completed
contemplates to replace that 10-year period with the the negotiation of an agreement between the EU and
recordkeeping period in the Member State of Identification. Norway on administrative cooperation, recovery assistance
and combating fraud in the field of VAT.43
Businesses should also consider the effect VAT/GST will have
on pricing and the customer experience. This is especially VAT on low value goods (LVG): the final
important when a vendor sells B2B and B2C and must frontier?
decide whether prices should be the same for both types of For simplification reasons, many countries exempt the
sales or whether a different price point should be adopted. importation of certain goods for which value is under a
Businesses should further review contracts and general specified threshold (e.g., between EUR10-20 in the EU and
terms and conditions once VAT/GST obligations are triggered 1,000 Australian dollars (AUD) in Australia on the basis that
to clarify the VAT/GST obligations of each party, especially the administrative and compliance costs of collecting the VAT
when the law provides for a VAT/GST inclusive computation due would be higher than the VAT collected.
(e.g., Russia). Finally, businesses should be aware that
because these rules are relatively new, guidance available The problem in these cases is that the significant growth in
with respect to audits of nonresident vendors of digital the importation of exempt LVG is allegedly affecting domestic
services is relatively sparse. Given that the VAT enforcement brick-and-mortar retailers and reducing tax revenues. In
authority remains with the Member State of Consumption, the EU, the number of small consignments (i.e., under the
taxpayers are potentially subject to multiple audits, each exemption threshold) that entered from outside the EU
following potentially different administrative procedures, rose from 30 million in 1999 to almost 115 million in 2013.44
rules, and potential penalties. Similarly, in Australia, in 2009–2010, the total volume of
air cargo imports reported was 11.2 million consignments,
Finally, while there is not yet a significant body of audit the majority of which were under the threshold for private
experience dealing with digital goods and services, tax importation of goods. Only one year later, the total volume
authorities have started to build specialized teams targeting of air cargo imports rose to 13.9 million consignments.45 To
nonresident vendors of digital services. For instance, on address this situation, the OECD has proposed four different
7 September 2016, the German federal financial court held options, among which the “Vendor Collection Model” (i.e.,
that a US- based online dating platform was subject to VAT the non-resident vendor is required to charge, collect, and
in Germany because it provided digital services to German remit the VAT in the country of importation) appears to be the
customers.42 Along with an increased audit presence, it is one preferred by most countries that are in the early process
reasonable to believe that enforcement of these new rules of implementing new rules on this topic.

41
EU Directive 2006/112/EC, art. 369.
42
Supreme Tax Court Ruling, XI R 29/14 (June 1, 2016) (published on 7 September, 2016); see William Hoke, US-Based Online Dating Platform Is
Subject to VAT, German Court Says, 2016 WTD 179-10 (15 Sept. 2016).
43
European Commission, EU-Norway agreement on VAT cooperation initialed, available at https://ec.europa.eu/taxation_customs/node/949_en.
44
European Commission, Assessment of the application and impact of the VAT exemption for importation of small consignments (2015), available at
https://ec.europa.eu/taxation_customs/sites/taxation/files/docs/body/lvcr-study.pdf.
45
See Australian Government, Dep’t of Immigration and Border Protection, Low value import threshold Taskforce, https://www.border.gov.au/Busi/
Duty/Low-; Laura Mattes, VAT Aspects of Cross-Border Transactions in the BEPS Era, IBFD Int’l VAT Monitor, May/June 2016.

Australia will be the first country to apply GST on the be in the scope of foreign tax authorities. These taxpayers
importation of LVG effective 1 July 2018. Australia will require will have to go through the same iterative process as their
either the vendor, the e-marketplace, or the freight carrier digital services counterparts and face the same compliance
(depending on the specific facts and circumstances) to requirements.
collect the import GST on these transactions.46 The EU VAT
proposal includes provisions that extend the VAT MOSS Further challenges: bitcoin, 3D printing,
mechanism to the import of LVG and hold the carrier liable crowdfunding and crowdsourcing
for the import VAT under certain circumstances.47 In the Beyond the issues discussed above, companies should
meantime, the UK has taken a unique approach to fight VAT also prepare for the challenges that some cutting edge
fraud involving LVG that could be followed by other countries. technological developments (e.g., digital currencies and
Since 2016, online marketplaces that provide a facility for UK 3D printing) and other disruptive business models (e.g.,
consumers to view and place orders for goods being offered crowdfunding and crowdsourcing) are beginning to pose for
for sale by overseas businesses (i.e., those not physically companies within the VAT/GST world.
located in the UK) may be held jointly and severally liable
for VAT unpaid by these overseas businesses.48 In addition, For several years, well known commercial retail organizations
Russia’s antimonopoly service recently announced that it have been accepting digital currency51 as payment for the
was working on a draft legislation that would impose VAT on purchase of goods and services. These digital currencies or
goods sold by foreign online retailers to Russian consumers.49 crypto-currencies have not received much attention from most
Finally, on 2 June 2017, the Swiss Federal Council clarified tax authorities, and their tax treatment is not yet clear. Should
that the amendments to the VAT computation threshold they be treated as regular currencies and legal tender? Should
computation would be delayed for mail order companies and a business mining (i.e., creating) and selling digital currency
would be effective 1 January 2019.50 Consequently, mail- charge VAT/GST on the value of the digital currency sold? If
order companies will be liable to tax from 2019 if their annual digital currency is not legal tender, should it be considered
turnover from small consignments that are import-tax-free as a “voucher”? Could it be regarded as a type of “digital
is at least CHF 100,000. Such mail-order companies will good” itself that would create a “barter transaction”? Some
themselves bill customers for VAT and the customers will no jurisdictions have provided guidance on at least some of these
longer have to pay the taxes and fees levied by customs upon questions. During October 2015, the Court of Justice of the
importation. European Union issued its first ruling52 on the digital currency
known as Bitcoin and held that transactions involving the
These new rules will affect a new set of businesses that buying and selling of Bitcoins are exempt from VAT under the
have until now been mostly spared by these growing VAT/ provision concerning transactions relating to “currency, bank
GST challenges. Online retailers and freight carriers will soon notes and coins used as legal tender.” On 27 March 2017, Japan

46
arliament of Australia; Treasury Laws Amendment (GST Low Value Goods) Bill 2017, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;qu
P
ery=Id%3A%22legislation%2Fbills%2Fr5819_first- reps%2F0000%22;rec=0.
47
Proposal for a Council Directive amending Directive 2006/112/EC and Directive 2009/132/EC as regards certain value added tax obligations for
supplies of services and distance sales of goods (Dec. 1, 2016).
48
HMRC, VAT Guidance: Overseas Business Using Online Marketplace to Sell Goods in the UK (last updated February 22, 2017).
49
Russian Legislation being Drafted to Impose VAT on Foreign Online Retailers (Mar. 16, 2017), Orbitax Daily News.
50
The Federal Council, Federal Council brings revised Value Added Tax Act into force (Jun. 2, 2017), available at https://www.admin.ch/gov/en/start/
documentation/media-releases.msg-id-66940.html.
51
The official website is https://Bitcoin.org/en. See also Aleksandra Bal, Stateless Virtual Money in the Tax System, 53 Eur. Tax’n. no. 7, at 351 (2013).
52
Court of Justice of the European Union PRESS RELEASE No 128/15 Luxembourg (Oct. 22, 2015) (Judgment in Case C- 264/14 Skatteverket v
David Hedqvist).

passed the 2017 tax reform bills that include amendments using specifically designed platforms that allow the peer-to-
exempting the sale of virtual currency from Japanese peer interaction between entrepreneurs and contributors
Consumption Tax effective 1 July 2017.53 Australia proposed (i.e., those that create a project and those that provide the
in its latest budget to treat digital currencies as money and financial support to that project, respectively). Crowdfunding
thus reverse the Australian Tax Office’s practice of taxing platforms generally receive a fixed amount of the contribution
transactions involving digital currencies.54 However, the made. Usually, a limited period of time is set up for the
answers to the aforementioned questions are, in most cases, funding, and small contributions from a large number of
not clear and rather speculative due to the general absence of parties are typically expected. Two main crowdfunding
specific legislation, official guidance, and case law.55 models can be identified: (1) non-financial return models, in
which the return may range from either nothing (donation)
Another challenge that businesses must be prepared to
to goods or services (reward-based model); and (2) financial
face is posed by 3D printing. This phenomenon may turn the
return models, in which a financial return is expected, either
manufacturing and distribution industries upside down and
a participation in the form of revenues or securities (crowd-
revolutionize longstanding business models. In the not-
investing), or interest on loans (crowd-lending).56
too-distant future, every person with a 3D printer at home
will be capable of making physical goods from a digital file In 2015, the EU Commission started to examine the VAT
downloaded from the internet. VAT/GST is a tax on the value implications of crowdsourcing.57 In its working paper, the
added by each actor in a supply chain. The current system commission (1) considered whether the reward constitutes
is largely premised on the notion that full value is delivered a sale of goods or services for VAT purposes; (2) considered
to the consumer. However, 3D printing may be disrupting whether the contribution should be considered as a
the traditional supply chain by moving the manufacturing payment on account before the goods or services are
activities from factories to the consumer’s printing devices. provided; (3) considered what the taxable base should be of
As a result, much of the taxable value added may migrate to the sale of goods or services; and (4) suggested potential
the end of the supply chain, thus increasing the number of VAT treatments for rewards of symbolic value. Concerning
potential “manufacturers.” Government and businesses will financial return models, the main questions that arise are:
have to find answers for a new set of issues, including: How
—— What should be the VAT treatment when the crowd-
will the VAT/GST be imposed? Who will be liable to collect
investing results in a participation in future earnings?
the tax? Who will effectively bear it? Would the owner of the
printer be considered a “business” or a “final consumer”? —— What should be the VAT treatment when the crowd-
investing is an investments in securities?
Crowdfunding is another innovation that will exponentially
increase the VAT/GST challenges of many companies. —— What is the VAT treatment of crowd-lending?
Crowdfunding generally refers to the process of raising
—— What should be the VAT treatment of intermediation
funds for a specific project via an open call on the internet,
services provided by online crowdfunding platforms?

53
KPMG, Japan E-Tax News No. 131, (Mar. 28, 2017), available at https://assets.kpmg.com/content/dam/kpmg/jp/pdf/jp-en-e- taxnews-20170328.pdf.
54
Numerous GST Changes Confirmed in Australian Budget, CCH Global Daily Tax News (May 12, 2017).
55
See Machiel Lambooij, Retailers Directly Accepting Bitcoins: Tricky Tax Issues?, IBFD Derivatives & Financial Instruments, May/June 2014
56
VAT Committee (Article 398 OF Directive 2006/112/EC) Working Paper No. 836, at 2-3.
57
VAT Committee (Article 398 OF Directive 2006/112/EC) Working Paper No. 836, at 5-19.

While most jurisdictions have not issued guidance on this Conclusion

topic, the Australian Tax Office found that the donation-based
In this article, we have highlighted the potential VAT/GST
model is not subject to GST, the reward-based model is
challenges that technological changes and improvements
subject to GST, and the equity- and debt-based models are
have created in recent years. As long as businesses go
akin to GST exempt financial transactions.58
through an iterative process and are capable of answering the
Similar challenges are posed by crowdsourcing (i.e., obtaining basic questions governing VAT/GST (i.e., who, what, where,
services, ideas, or content by soliciting contributions from a when, and how much), they should be able to identify their
large group of people, especially from the online community global VAT/GST footprint and related compliance obligations,
rather than from traditional employees or suppliers), which is regardless of the evolution of business models and laws.
a popular practice among businesses worldwide. Several tax
New technologies have also been used by governments
authorities have in recent years issued guidance, especially
to increase VAT/GST compliance and reduce VAT fraud. In
with respect to ride-sharing services, to clarify the VAT/
recent years, we have observed the spread of e-invoicing
GST responsibilities of the parties involved. For instance,
and electronic reporting. Audits are increasingly performed
in Australia, guidance clarifies that drivers of ride-sharing
using data and analytics tools, and real time reporting is no
services may be considered to be providing taxable travel
longer a dream, but already a reality in a few jurisdictions.
services for GST purposes and may thus be required to
In the future, it may well be that VAT/GST compliance will
register for GST purposes and to issue tax invoices upon
be simplified by systems allowing a direct and secure
the passenger’s request.59 Moreover, in its latest budget,
interchange between businesses and authorities, thus
Canada proposes to amend the definition of taxi business in
obviating the need for issuing invoices, filing returns, and
the Excise Tax Act, which would result in the drivers of ride
perhaps even audits. While new technologies may create
sharing services to share the same GST consequences as
challenges to the effective taxation of consumption, they may
taxi drivers and thus be liable to register for and collect GST
also be the key to reducing the administrative and compliance
on their services.60
cost of taxation.

The information in this article is not intended to be "written advice concerning one or more federal tax matters" subject to the requirements of section 10.37(a)(2) of
Treasury Department Circular 230 because the content is issued for general informational purposes only. The information contained in this article is of a general nature
and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax
adviser. This article represents the views of the author or authors only, and does not necessarily represent the views or professional advice of KPMG LLP.

58
Australian Tax Office, GST and Crowdfunding, https://www.ato.gov.au/Business/GST/In-detail/Rules-for-specific-transactions/GST-crowdfunding/
59
See, e.g., ATO, Providing Taxi Travel Services Through Ride-Sourcing and Your Tax Obligations, https://www.ato.gov.au/business/gst/in-detail/
managing-gst-in-your-business/general-guides/providing-taxi-travel-services-through-ride-sourcing-and-your-tax-obligations/.
60
See, e.g., Government of Canada, Budget 2017, Chapter 4 — Tax Fairness for the Middle Class, available at http://www.budget.gc.ca/2017/docs/plan/
chap-04-en.html.

VAT/GST and cross-border

supplies of services
Interpreting the survey’s findings
By Lachlan Wolfers, Indirect Taxes Regional Leader, Asia Pacific; David Duffy, Director, KPMG in Ireland;
and Peter Sanderson, Senior Manager, KPMG in Sweden

Introduction
KPMG International’s 2017 survey of the Value Added Tax (VAT) and Goods and Services
Tax (GST) treatment associated with cross-border supplies of services around the world is
among the largest of its kind ever attempted. Covering 52 countries, the survey covers all of
the major economies of the world, except the United States (US) given it has a State-based
sales tax system.

The purpose of carrying out the survey is, to put it simply, all while sitting in their bedroom in Mom and Dad’s house in
because there are major changes taking place to the VAT places like Silicon Valley in the US, Hangzhou in China, and
and GST treatment of cross-border supplies of services. Tel Aviv in Israel. The critical aspect of this is that the 18 year-
The primary area where those changes are taking place old tech savvy student may technically have the same or
concern electronic supplies of services, for example, in similar levels of compliance obligations as large multinational
areas like digital content such as films, music and news, data companies, given that they may have little or no control over
hosting and storage (e.g. cloud computing), online gaming, where their app is consumed around the world.
telecommunications, payment services and advertising, etc.
To highlight this point, KPMG’s Global Indirect Tax Services
The article1 in this publication entitled VAT/GST and the digital was recently engaged by a provider of online digital content,
economy: the untold story of global challenges, highlights who wanted to understand their VAT/GST compliance
the challenges for businesses attempting to comply with the obligations “in every country around the world”. When we
VAT and GST laws around the world and outlines the steps questioned the client about whether they truly meant “every
required to do so. For clients of KPMG member firms, many country”, their answer was “Yes”. They really did want to
of whom are multinational companies, complying with their understand whether they had to pay VAT or GST in relation
obligations around the world, especially in such a dynamic to sales of digital content to consumers in North Korea
and evolving commercial and regulatory environment, is (notwithstanding the obvious barriers to such sales actually
immensely challenging. It is hoped that this survey goes occurring), and when we pointed out that this would not be
some way towards providing them with a snapshot of their limited to just “countries” but would also include separate
key VAT and GST compliance obligations. taxing jurisdictions in little known locations such as Niue and
Labuan, their answer was that they needed to understand
Importantly though, what makes this area of VAT or GST so
this too. While this provided the KPMG team with some
immensely challenging is that, in many cases VAT and GST
interesting challenges, not to mention for some of us a
compliance obligations can arise for organizations ranging
refresher course in the geographies of the world, the key
from household names such as Amazon, Alibaba, Google and
point here is that these rules do potentially require global
Facebook, through to 18 year-old tech savvy students who
compliance.
develop a successful app which they sell on an app store,

1
PMG in the US (2017), VAT/GST and the digital economy: the untold story of global challenges, Philippe Stephanny and Juan Vazquez (extern),
K
KPMG LLP.

Methodology and Development (OECD) and the G20 in response to the

tax problems arising from the digitization of the economy.2
This survey was carried out by KPMG International in
However, to describe this as a tax problem is perhaps inapt.
conjunction with KPMG member firms around the world. The
Rather, this is a fundamental change to the nature of the
survey does not seek to apply subjective criteria. Rather, the
global economy (sometimes now referred to as the fourth
survey asks questions which bear upon the key compliance
industrial revolution) which has triggered the need for
obligations which online providers of digital services need
changes to the tax regulatory environment.
to understand. Issues such as whether those obligations
apply not only to business-to-business (B2B) sales but As the OECD/G20 report so succinctly put it, “the digital
also to business-to-consumer (B2C) sales, whether there economy is now the real economy”. Put simply, it is the idea
are minimum registration thresholds, the scope of what that our tax rules need to be updated in recognition of the
digital services are taxed, tax invoicing obligations, etc., fact that an 18 year-old student sitting in a bedroom in their
and perhaps most importantly given the evolving regulatory parent’s house can derive significant income and carry out
environment, whether there are changes on the horizon. business activities for which taxes on consumption should be
levied. Historically, our tax rules have largely been predicated
We anticipate that this survey is being launched mid-way
on the assumption that to carry out such business activities
through the cycle of implementation of these measures on
requires the establishment of a shop front (or ‘bricks and
a global basis. In other words, we are in the midst of frenetic
mortar’ business), the hiring of staff, and customers who
changes to the regulatory environment, and therefore it
walk through the door.
is timely to pause for a moment and assess whether the
compliance regimes being implemented around the world While much of the OECD’s focus has been on corporate
are consistent or not, and whether further change is still income tax issues, the world of indirect taxes has not been
required. immune. However, where perhaps the indirect tax position
is more aligned in terms of its goals than in corporate taxes,
This survey is intended to be up to date as at 1 July 2017.
is in terms of the principles which should be applied. As
Inevitably though, given the size and scale of this survey,
Professor Rebecca Millar puts it so eloquently:3
there may be instances where changes have since taken
place, or errors, inaccuracies or minor nuances missed. Given “… the conclusion that “something needs to be
this, it is necessary to obtain professional advice before done” simply does not have the same significance
acting on any of the survey findings. for VAT as it does for income tax. This is not because
VAT on global digital transactions is easy to collect: it
OECD-G20 recommendations is not. Nor is it because VAT raises different collection
Before setting out the survey findings, it is imperative to problems than income tax: for the most part, it does
go back to the primary source(s) for all of the regulatory not. What is different about VAT is the almost universal
changes we are seeing. That source is the report which has agreement on the substantive jurisdictional principle
been issued by the Organisation for Economic Co-operation that should be used to determine the tax base. Some

2
OECD (2015), “Addressing the Tax Challenges of the Digital Economy, Action 1 — 2015 Final Report”, OECD/G20 Base Erosion and Profit Shifting
Project, OECD Publishing, 2015.
3
Millar, R. (2014). Looking ahead: potential global solutions and the framework to make them work. The Future of VAT in a Digital Global Economy
2014, Vienna, Austria: Presentation.

countries might pay lip service to the destination 2. B2C services which are consumed on the spot, such
principle, particularly countries with limited tax as personal services, accommodation and restaurants,
collection capacity and a high reliance on VAT to meet should be taxed where the service is rendered;
their revenue needs. Other countries — or their tax
3. Non-resident suppliers of B2C services should register
administrations and/or courts — might disagree about
for and charge VAT in the country where the customer
what the destination principle requires in particular
is located, ideally through simplified registration and
circumstances. Nonetheless, there is little or no
compliance regimes;
significant disagreement on the fundamental principle.
Nor is there any significant disagreement about the 4. Resident business recipients of B2B services should self-
most important aspect of the neutrality principle, which assess VAT using a reverse charge.
entails the notion that there should generally be no tax
burden on business-to-business (B2B) transactions Key survey findings
under a VAT. Thus, whatever it is that needs to be done, With this background in mind, we now turn to consider five
it is unlikely to involve a fundamental re-think of the key themes which arise from the survey.
jurisdictional basis upon which decisions are made
about which country has the right to tax consumption.”
These principles have now found their way into the OECD’s
International VAT/GST Guidelines.4 In this regard, it is
Theme 1
important to recognize that the OECD is not a regulatory The intended policy outcomes are largely aligned,
body — it merely makes recommendations on policy issues but the mechanisms to achieve them are not
for governments to consider, and furthermore membership being implemented consistently
of either body is not truly global. Notwithstanding this, the
When we look at the OECD’s recommendations, what we
OECD has taken a global leadership role in this area and has
see is a relatively clear statement of the intended policy
perhaps been responsible for achieving a significantly greater
outcomes, but a less than consistent implementation of
level of alignment in terms of policy outcomes than would
these mechanisms. Challenges in terms of implementation
have otherwise happened.
seem to be a function of three main factors:
The key guidelines proposed by the OECD in the International
1. In some areas, the OECD has perhaps been too flexible
VAT/GST Guidelines as they pertain to VAT/GST and cross-
in its recommendations, with the result that countries are
border digitized services are helpfully set out in the article5
able to ‘pick and choose’ too much in the implementation
in this publication entitled VAT/GST and the digital economy:
of these measures, resulting in unnecessarily high levels
the untold story of global challenges, and is therefore not
of inconsistency. Having said that, the OECD is not a
repeated in detail again here. It merely suffices to note the
regulatory body and therefore its approach in providing
principles may be succinctly stated as follows:
flexibility is understandable;
1. B2B and B2C transactions should generally be taxed in
2. Some countries have simply failed to implement, or failed
the country where the customer is established (except for
to properly implement, the OECD’s recommendations at
those consumed ‘on the spot’);
this stage. This will hopefully change over time;

4
ECD (2017), International VAT/GST Guidelines, OECD Publishing, Paris.
O
5
KPMG in the US (2017), VAT/GST and the digital economy: the untold story of global challenges, Philippe Stephanny and Juan Vazquez (extern),
KPMG LLP.

3. The measures proposed by the OECD may require too The advantage which exists in the European Union (EU) is
significant a change to a country’s own tax system to fully that the core rules are not only harmonized, but that they
implement these measures. As such, some countries have arranged themselves to offer a simplified collection
seek to find new ways to implement the OECD’s mechanism through the “Mini One Stop Shop” (or MOSS as
recommendations in a way which is more workable under it is known). This means, essentially, that an EU or non-EU
their tax legislative structures. supplier can register for VAT in a single country in the EU and
use that registration to remit the VAT due on their sales to the
This inconsistency poses additional challenges for global
various EU tax authorities.
businesses in ensuring compliance with tax rules in multiple
jurisdictions. While there is a broad alignment to uniformly If we contrast that with the position in other regions of the
apply a consumption based taxation principle, non- world, such as in Asia Pacific or Latin America, then the
implementation and variations in implementation mean that relative challenge and disadvantage is stark. Foreign suppliers
we remain far from harmonized. For example, a certain type of digitized services will, at least in theory, be obliged to
of B2C service may be taxable in Australia under provisions register and account for VAT/GST in each country in which
capturing all B2C services, taxable in the EU as an electronic their services are consumed.
service, not taxable in South Africa as it does not fall under
Thankfully though, as the survey highlights, a number of
the local electronic service definition, and not taxable in Brazil
countries have responded to this problem, principally in two
given that consumption based taxation is yet to be introduced
key respects. First, they have applied de minimis thresholds
for B2C services. As a consequence, businesses are required
below which registration and VAT/GST compliance obligations
to actively manage and monitor their global obligations to
do not apply. This means, for example, that a foreign supplier
ensure compliance in this changing and non-harmonized
selling their digitized services to consumers in Australia is
environment.
not required to register and account for GST if their turnover
is below AUD75,000 per annum (approximately USD60,000)
and similarly in Japan where their turnover is below 10 million
Theme 2 Japanese yen (JPN) (approximately USD91,000).
Second, many countries have also implemented either
The EU has a significant advantage in their
optional or compulsory forms of simplified VAT/GST
implementation of these measures
registration procedures. That is, those countries have offered
The OECD/G20 report recognizes the practical difficulties a streamlined VAT or GST registration process, where the
which tax authorities will have in the enforcement of any filing of VAT/GST returns merely reports output tax liabilities.
new measures to tax cross border B2C supplies of digitized Given that the premise for these measures is that foreign
services, given that in almost all cases the offshore service suppliers of digitized services do not have a permanent
provider will have no permanent establishment or other establishment (PE) in that country, the amount of input tax
presence in the jurisdiction. The OECD/G20 report even goes potentially ‘lost’ through a simplified registration process will
so far as to say that compliance with these requirements is often be relatively low.
“essentially voluntary”.6

6
Ibid at p122.

Notwithstanding these simplification measures, purely from Interestingly though, the survey shows that withholding
the perspective of compliance they do place the EU at an systems tend to be more commonly used amongst
advantage relative to other regions because of the ability communist/socialist countries (China, Russia and though
to capture a whole trading bloc in one hit. It does beg the not surveyed, Vietnam too), and similarly are more common
question whether other trading blocs around the world may amongst countries with currency controls (for example,
respond by implementing similar measures, as has been China, Russia, and again Vietnam). A possible explanation for
envisioned within the GCC VAT Framework, though the this is that enforcement is better able to be achieved where
collection of tax by one country on behalf of another is not the withholding of taxes is applied as a precondition or as part
usually seen in these arrangements. of the currency clearance process, which is certainly how it
works in China. The EU, on the other hand, adopts the reverse
charge procedure for purchases of services by business
customers from foreign suppliers.
Theme 3 To date, the OECD appears to be relatively silent on the
The scope is expanding appropriateness of withholding systems for VAT/GST. While
the OECD’s International VAT/GST Guidelines do express a
One trend we have noted is that countries which were
preference for reverse charge, one challenge with reverse
‘early adopters’ of these measures have tended to tax only
charge systems is that they are routinely overlooked by
a narrow or specific scope of services, whereas those
finance staff, given that the receipt of an invoice is not
countries which are more recent adopters have applied a
ordinarily a trigger for accounting for output tax liabilities.
broader scope. Take for example, South Africa and Japan
By contrast, withholding systems have the propensity to
which initially applied these measures to specific services
catch foreign service providers unaware, resulting in them
only, whereas more recent adopting countries like Australia,
economically bearing the tax. Similarly, withholding systems
New Zealand and Russia have cast the net wider.
can cause accounting problems too, given that invoices
While there is no ‘right’ or ‘wrong’ answer here, in our view are short paid which later then need to be reconciled or
those countries initially adopting narrower or more targeted written off.
measures will inevitably need to expand their scope, as the
range of services being delivered across borders digitally
expands with technological advancement.
Theme 5
Placing trust in those who pay the tax
The final, and in some ways, most important theme is the
Theme 4 new and novel ways in which governments around the world
Reverse charge versus withholding on B2B supplies are trying to enforce the collection of tax on cross border B2C
supplies of digitized services.
In a B2B context, the survey highlights the fact that there
are two main mechanisms used throughout the world for As the OECD/G20 report notes, measures to require the
the collection of VAT/GST on cross-border B2B supplies. The private consumer to remit or self-assess the VAT/GST have
most common method is through the adoption of a reverse “proven to be largely ineffective”.7 Similarly, the OECD/G20
charge, whereby the VAT/GST is effectively self-assessed report acknowledges that placing compliance obligations
by the recipient who is located in the country in which the on offshore businesses (especially those who are small-
consumption takes place. The other method is through the to-medium in size) is “essentially voluntary”.8 However, the
use of VAT/GST withholding systems, in which the VAT/GST is OECD/G20 report also acknowledges that “high-profile
withheld from the price paid to the service provider. operators, which occupy a considerable part of the market,
wish to be seen to be tax-compliant notably for reputational
In each case, neutrality is only achieved by ensuring that reasons.”9
services acquired for use in fully taxable businesses are
eligible for credits (or in some cases, not subject to a reverse This has led some countries to investigate new and novel
charge in the first place). ways of maximizing compliance. One approach has resulted

7
Ibid at p.121.
8
Ibid at p.122.
9
Ibid at p.122.

in some countries requiring online marketplaces authorities effectively divert the VAT/GST and thereby obtain
(e.g., companies such as Amazon, Apple and Alibaba) to a first priority over the VAT/GST liability collected. It is akin to
account for the VAT/GST not only in respect of online sales what happens in many countries with personal income taxes
they make on their own account, but also in respect of online on salaries and wages being deducted at source, usually on a
sales they facilitate through their platforms. Already we are provisional basis.
seeing Australia, India and the EU legislate to this effect.
In our view, both of these methods may grow until such
The theory behind this is that it is more efficient and perhaps
time as technological advancement better enables point
more effective for tax authorities to collect the revenue from
of sale tax collection on B2C transactions, and blockchain
a smaller group of marketplace operators than it is to impose
facilitated certifications overcome the need for remittances
registration and compliance obligations on many of the small
and crediting in B2B transactions. A discussion of these
vendors who sell their goods or services through those online
developments is unfortunately beyond the scope of
marketplaces. While debating the merits of these measures
this article.
is beyond the scope of this article, a key concern which has
been highlighted is that the de minimis measures effectively
cease to apply because the turnover of the small vendors is
Conclusion
aggregated with that of the marketplace operators. The result The work carried out by the OECD in terms of its International
is an unequal playing field — the small vendors are effectively VAT/GST Guidelines have gone a long way to establish a
penalized in having VAT or GST imposed by using marketplace clear and consistent framework for the taxation of cross-
operators whereas no VAT or GST would be imposed on a border supplies of services at both a B2B and a B2C level.
standalone basis. However, and in spite of the efforts of the OECD, the survey
highlights high levels of inconsistency in the implementation
The second novel development is in the growing use of ‘split of these guidelines (especially outside of the EU), which
payment’ methods. Broadly speaking, these are measures will likely result in both excessive compliance costs for
designed to require purchasers of services (and potentially those businesses who do comply, and high levels of non-
goods too), or potentially the payment processing company compliance for those who pragmatically conclude that the
handing the payment, to effectively divert the VAT or GST costs of compliance outweigh the risks and consequences
included in the purchase price directly to a separate bank of breaching them. Perhaps a new approach is needed here,
account held for the benefit of the tax authority. The objective along the lines of the OECD leaving less room for flexibility
being that the tax authority collects the VAT or GST at or in implementation by countries, coupled with greater levels
near to the point of sale directly from the purchaser, thereby of cooperation being adopted in the implementation of these
providing greater protection in the event of non-compliance, measures by various trade blocs outside the EU.
default or insolvency by the seller.
The split payment method is currently being adopted in Italy
(in the context of B2B transactions with public agencies),
and is at various stages of consultation or implementation
in places like the United Kingdom (B2C online sales only),
Poland (in a B2B context from 1 January 2018), and Romania
(B2B and B2C, likely to be compulsory from 1 January 2018).
In its broadest form, what both the ‘marketplace operator’
and ‘split payment’ methods are about is avoiding a situation
where trust to pay the tax is placed in the hands of smaller
vendors. In the marketplace operator model, the obligation
to account for the tax is placed in the hands of what (is
perceived to be) a large company with significant resources
and a lower level of risk of default or fraud. The split payment
method effectively goes one step further and concedes that
a trust based system is inherently prone to risk, so the tax

Summary of key findings

Supplies of e-services to consumers (B2C) Supplies of e-services to businesses (B2B)
(see footnote 1) (see footnote 2)

Country 1(a). Is a non-resident 1(b). If there is no current 1(c). Is an invoice 2(a). Is a non-resident 2(b). If there is no current
supplier (see footnote requirement, is there any compliant with the supplier of e-services requirement, is there any
3) of e-services to anticipated change to that VAT/GST law in the to business customers anticipated change to that
consumers located in position? customer's country located in this country position?
this country obliged to required? obliged to register and/
or account for local VAT/
register and/or account GST on such supplies in
for local VAT/GST on this country?
such supplies in this
country?

Andorra Yes Not applicable — Requirement Yes No No

is already in place
Argentina No No No No No

Australia Yes Not applicable — Requirement No No No

is already in place
Austria Yes Not applicable — Requirement No No No
is already in place
Bahamas Yes Not applicable — Requirement Yes Yes Requirement is already in
is already in place place

Belarus No There is a scheduled No No No

introduction of such a
requirement on 1 January 2018
Belgium Yes Not applicable — Requirement No No No
is already in place

Brazil No No No No No

Bulgaria Yes Not applicable — Requirement Yes No No

is already in place

Canada Depends on all of the In its 2014 federal budget, Yes Depends on all of the In its 2014 federal budget,
facts the government announced facts the government announced
consultation on the issue consultation on the issue
China No No Not applicable No No

Colombia No There is a scheduled Yes No There is a scheduled

introduction of such a introduction of such a
requirement on 1 July 2018 requirement
Croatia Yes Not applicable — Requirement Yes No No
is already in place

Cyprus Yes Not applicable — Requirement Yes No No

is already in place

Czech Republic Yes Not applicable — Requirement No No No

is already in place

Denmark Yes Not applicable — Requirement Yes No No

is already in place

Egypt Yes Not applicable — Requirement Yes Yes Not applicable - Requirement
is already in place is already in place

Finland Yes Not applicable — Requirement Yes No No

is already in place

France Yes Not applicable — Requirement No No No

is already in place

Germany Yes Not applicable — Requirement Yes No No

is already in place

Note: See page 26 for footnotes.

Supplies of e-services Where there is a current or future requirement for non-resident suppliers to register and/or account for local
to businesses (B2B) VAT/GST or a customer VAT withholding requirement:
(see footnote 2)
Country 2(c). If there is not a 3(a). When did/will that 3(b). What is the applicable 3(c). Is simplified or 3(d). Does the
requirement for the requirement come into annual turnover threshold (in standard registration requirement apply to all
non-resident supplier effect? USD) for that requirement to required? e-services?
to register, are the apply? (see footnote 7)
services subject to any
of the following by the
customer?

i) VAT/GST withholding
ii) Reverse charge VAT/
GST
Andorra Reverse charge 1 January 2013 USD47,516 Standard Yes

Argentina Reverse charge Not applicable Not applicable No registration is required Not applicable

Australia No 1 July 2017 USD60,043 Optional Yes

Austria Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)
Bahamas Not applicable 1 January 2015 USD100,000 Standard Yes

Belarus Reverse charge 1 January 2018 Nil Optional No (footnote 6)

Belgium Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Brazil Not applicable Not applicable Not applicable No registration is required Not applicable

Bulgaria Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Canada Reverse charge Upon the introduction of GST General rules apply Standard Yes

China VAT withholding Not applicable Not applicable No registration is required Yes

Colombia Reverse charge 1 July 2018 Nil Simplified Yes

Croatia Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Cyprus Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Czech Republic Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Denmark Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Egypt Not applicable 8 September 2016 USD28,323 Standard Yes

Finland Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

France Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Germany Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Note: See page 26 for footnotes.

Summary of key findings

Supplies of e-services to consumers (B2C) Supplies of e-services to businesses (B2B)
(see footnote 1) (see footnote 2)

Ghana Yes Not applicable — Requirement Yes Yes Requirement is already in

is already in place place

Iceland Yes Not applicable — Requirement Yes No No

is already in place

India Yes Not applicable — Requirement Yes No No

is already in place

Indonesia No No Not applicable No No

Ireland Yes Not applicable — Requirement No No No

is already in place

Isle of Man Yes Not applicable — Requirement No No No

is already in place

Italy Yes Not applicable — Requirement No No No

is already in place

Japan Yes Not applicable — Requirement Yes No No

is already in place

Kenya Yes Not applicable — Requirement Yes No No

is already in place

Lithuania Yes Not applicable — Requirement No No No

is already in place

Luxembourg Yes Not applicable — Requirement Yes No No

is already in place

Malaysia No Yes Yes No Yes

Malta Yes Not applicable — Requirement Yes No No

is already in place

Mexico No No Not applicable No No

Netherlands Yes Not applicable — Requirement No No No

is already in place

New Zealand Yes Not applicable — Requirement No No No

is already in place

Norway Yes Not applicable — Requirement No No No

is already in place

Poland Yes Not applicable — Requirement Yes No No

is already in place

Portugal Yes Not applicable — Requirement Yes No No

is already in place

Note: See page 26 for footnotes.

i) VAT/GST withholding
ii) Reverse charge VAT/
GST
Ghana Not applicable 1 January 2014 USD27,096 Standard Yes

Iceland Reverse charge 1 November 2011 USD18,692 Standard Yes

India Reverse charge 1 July 2017 Nil Simplified No

Indonesia Reverse charge Not applicable Not applicable No registration is required Not applicable

Ireland Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Isle of Man Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Italy Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Japan Reverse charge 1 October 2015 USD90,482 Standard No

Kenya Reverse charge 2 September 2013 KES5 million Standard No

Lithuania Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Luxembourg Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Malaysia Reverse charge Not applicable Not applicable No registration is required Not applicable

Malta Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Mexico No Not applicable Not applicable No registration is required Not applicable

Netherlands Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

New Zealand No 1 October 2016 USD43,530 Simplified Yes

Norway Reverse charge 1 July 2011 USD6,341 Optional No (footnote 6)

Poland Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Portugal Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Note: See page 26 for footnotes.

Summary of key findings

Supplies of e-services to consumers (B2C) Supplies of e-services to businesses (B2B)
(see footnote 1) (see footnote 2)

Romania Yes Not applicable — Requirement Yes No No

is already in place

Russia Yes Not applicable — Requirement No No No

is already in place

Serbia Yes Not applicable — Requirement No No No

is already in place

Singapore No There is a general proposal or Not applicable No There is a general proposal or

review by the authorities as to review by the authorities as
whether to introduce such a to whether to introduce such
requirement. a requirement.
Slovakia Yes Not applicable — Requirement No No No
is already in place

Slovenia Yes Not applicable — Requirement Yes No No

is already in place

South Africa Yes Not applicable — Requirement Yes Yes Requirement is already in
is already in place place

South Korea Yes Not applicable — Requirement No No No

is already in place

Spain Yes Not applicable — Requirement Yes No No

is already in place

Sweden Yes Not applicable — Requirement No No No

is already in place

Switzerland and Yes Not applicable — Requirement Yes No No

Liechtenstein is already in place

Tanzania Yes Not applicable — Requirement Yes Yes Requirement is already in

is already in place place

Thailand No There is a draft legislative Yes No A draft legislative proposal to

proposal to introduce such a introduce such a requirement
requirement
Turkey No No No No No

United Kingdom Yes Not applicable — Requirement No No No

is already in place

Footnotes
1. The reference to "consumer" and "B2C" generally refers to a private individual but might also include companies, organizations or other bodies which are not regarded
as carrying on a business for VAT/GST purposes in the recipient country (which would need to be confirmed on a case-by-case basis)

2. The reference to "business customer" and "B2B" generally refers to a business entity registered for VAT/GST purposes in the recipient's country but might also include
other companies, organizations or bodies which are not already VAT/GST registered in the recipient country (which would need to be confirmed on a case-by-case basis)

3. The reference to "non-resident supplier" generally means a supplier of the services which does not have a permanent or fixed establishment in the relevant country where
the customer is based, as the term "establishment" is defined or understood in the recipient country (which would need to be confirmed on a case-by-case basis)

4. There was already a requirement for suppliers established in countries outside the EU to account for local VAT on supplies of e-services to EU-based consumers in the
country where the consumer was permanently resident, prior to 1 January 2015. This requirement typically applied from 1 July 2003 or the date the relevant country
joined the EU if later than 1 July 2003.

i) VAT/GST withholding
ii) Reverse charge VAT/
GST
Romania Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Russia VAT withholding 1 January 2017 Nil Simplified Yes

Serbia No 1 January 2017 Nil Standard Yes

Singapore No Changes are under Not applicable No registration is required Not applicable
consideration

Slovakia Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Slovenia Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

South Africa Not applicable 1 June 2014 USD3,802 Standard No

South Korea Reverse charge 1 July 2015 Nil Simplified No

Spain Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Sweden Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

Switzerland and Reverse charge 1 January 2010 USD103,685 Standard No

Liechtenstein (Footnote: applies to worldwide
turnover from 1 January 2018)
Tanzania Not applicable 1 July 2015 Nil Standard Yes

Thailand Reverse charge Not yet known Not applicable No registration is required No

Turkey Reverse charge Changes are under Not applicable No registration is required Not applicable
consideration

United Kingdom Reverse charge 1 January 2015 (footnote 4) Nil Standard registration or Yes (footnote 6)
MOSS (footnote 5)

5. MOSS refers to the 'Mini One Stop Shop'. a VAT filing simplification in the EU for non-resident suppliers of telecommunication, broadcasting and electronically
supplied services to consumers in the EU.

6. The meaning of 'e-services' or 'electronically supplied services' is defined under local VAT law. For example, under the EU VAT Directive, which applies to all EU
member states.

7. Amounts stated in USD for ease of comparison and are illustrative only based on recent exchange rates. Consult relevant country page for threshold in local currency.

Andorra
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into 1 January 2013
is a current effect?
or future
What is the applicable annual turnover EUR40,000 (amount stated exclusive of VAT)
requirement
threshold (in local currency) for that
for non-
requirement to apply?
resident
suppliers to Is simplified or standard registration required? Standard
register and/
or account
for local VAT/
GST or a Does the requirement apply to all e-services? Yes
customer VAT
withholding
requirement:

Argentina
Supplies of Is a non-resident supplier of e-services to No
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the Argentinian customer is obliged to self-
e-services to business customers located in this country assess for VAT on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into No requirement exists.
is a current effect?
or future
What is the applicable annual turnover No registration or reporting obligation exists.
requirement
threshold (in local currency) for that
for non-
requirement to apply?
resident
suppliers to Is simplified or standard registration required? No registration is required.
register and/
or account
for local VAT/ Does the requirement apply to all e-services? No registration requirement exists.
GST or a
customer VAT
withholding
requirement:

Australia
Supplies of Is a non-resident supplier of e-services to Yes, from 1 July 2017, GST applies to services
e-services to consumers located in this country obliged to that are supplied electronically by non-residents
consumers register and/or account for local VAT/GST on who do not have a permanent establishment
(B2C) such supplies in this country? (“PE”) for GST purposes in Australia where the
supply is made to an Australian end consumer
(i.e. an Australian resident who is not registered
for GST).
From 1 July 2017, non-resident suppliers without
a GST PE are required to register for GST if the
B2C supplies they make to Australian consumers
meet or exceed AUD75,000 in a 12 month period
(regardless of where the service is performed).
Prior to 1 July 2017, non-resident suppliers
without a GST PE were required to register for
GST if the electronic services supplied using
Australian servers met or exceeded AUD75,000
in a 12 month period.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, where these supplies are made to Australian-
e-services to business customers located in this country based business recipients (that are registered for
businesses obliged to register and/or account for local GST), the supplies will not be subject to GST.
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into 1 July 2017
is a current effect?
or future
What is the applicable annual turnover AUD75,000
requirement
threshold (in local currency) for that
for non-
requirement to apply?
resident
suppliers to
register and/
or account
for local VAT/
GST or a
customer VAT
withholding
requirement:

(Continued Is simplified or standard registration required? It is optional. From 1 July 2017, non-resident
from the entities that are making taxable supplies to
previous Australian consumers have the option to register
page) for GST under the normal rules or under a
Where there simplified registration process.
is a current If the simplified GST registration is chosen the
or future entity will only need to report GST payable on
requirement sales (and cannot claim any GST credits) on a
for non- quarterly basis.
resident
Does the requirement apply to all e-services? Yes
suppliers to
register and/
or account
for local VAT/
GST or a
customer VAT
withholding
requirement:

Austria
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Austria.
(B2C) such supplies in this country? However, a VAT registration in Austria can be
avoided through the use of the Mini One Stop
Shop (MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Austria from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Austria from suppliers
resident established in a non-EU country.
suppliers to
register and/
or account What is the applicable annual turnover There is no minimum threshold.
for local VAT/ threshold (in local currency) for that
GST or a requirement to apply?
customer VAT
Is simplified or standard registration required? Non-resident vendors have the option to register
withholding
either in each EU member state where B2C sales
requirement:
are made, in which case the registration would
be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Bahamas
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes, Bahamas has two types of VAT compliant
in the customer's country required? invoices — a "VAT Invoice" and a "VAT Sales
Receipt". The VAT Invoice is used for B2B
transactions and a VAT Sales Receipt is used for
B2C transactions.
Supplies of Is a non-resident supplier of e-services to Yes, the self-reporting requirements place the tax
e-services to business customers located in this country obligation jointly and severally on the importer
businesses obliged to register and/or account for local and recipient and not on the vendor. This creates
(B2B) VAT/GST on such supplies in this country? a potential double taxation problem. Furthermore,
only services provided by electronic commerce
are subject to the mandatory registration rule.
Foreign suppliers of goods via the internet are not
required to register. Supplies of intangible rights
have not been addressed (e.g. digital content or
media). Greater clarity and certainty from the Tax
Authorities is needed.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
If there is not a requirement for the non- Not applicable
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into 1 January 2015 — with the introduction of VAT.
is a current effect?
or future
requirement
for non- What is the applicable annual turnover 100,000 Bahamian dollars (BSD) — Annual
resident threshold (in local currency) for that turnover is based on actual or expected turnover.
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Standard. Foreign electronic commerce suppliers
or account will need to obtain a business license prior to
for local VAT/ registering for VAT.
GST or a
customer VAT Does the requirement apply to all e-services? Yes
withholding
requirement:

Belarus
Supplies of Is a non-resident supplier of e-services to No, up to 31 December 2017.
e-services to consumers located in this country obliged to Yes, from 1 January 2018.
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any From 1 January 2018, non-resident suppliers to
anticipated change to that position? Belarusian individuals are required to register for
VAT for B2C electronically supplied services.
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into 1 January 2018
is a current effect?
or future
requirement
for non- What is the applicable annual turnover There is no minimum threshold.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Optional.
or account
for local VAT/ Does the requirement apply to all e-services? No
GST or a
customer VAT
withholding
requirement:

Belgium
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Belgium.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No, there is no requirement to issue an
in the customer's country required? invoice for VAT purposes on supplies to private
consumers.
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Belgium from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Belgium from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Brazil
Supplies of Is a non-resident supplier of e-services to No
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, as a general rule, only companies
e-services to business customers located in this country incorporated in Brazil are subject to taxation as
businesses obliged to register and/or account for local residents, as in principle, Brazilian companies
(B2B) VAT/GST on such supplies in this country? must register for tax purposes. The Brazilian
Civil Code (BCC) prohibits foreign entities from
operating in Brazil without authorization which is
granted by means of establishing a branch. The
branch is taxable in Brazil in the same manner as
a Brazilian legal entity.
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- Not applicable
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into No requirement exists.
is a current effect?
or future
requirement
for non- What is the applicable annual turnover No registration or reporting obligation exists.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Not applicable
or account
for local VAT/ Does the requirement apply to all e-services? Not applicable
GST or a
customer VAT
withholding
requirement:

Bulgaria
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Bulgaria.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Bulgaria from suppliers
or future established in another EU member state.
requirement —— 1 January 2007 for B2C supplies of
for non- e-services to consumers in Bulgaria from
resident suppliers established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Canada
Supplies of Is a non-resident supplier of e-services to It will depend on the exact facts and
e-services to consumers located in this country obliged to circumstances. In general, a non-resident
consumers register and/or account for local VAT/GST on vendor who carries on business in Canada is
(B2C) such supplies in this country? required to register for GST and collect GST if
the non-resident vendor makes taxable supplies
in Canada. The Canada Revenue Agency (CRA)
has provided a list of various factors to consider
when making this determination, including
among others, the place of delivery, the place of
payment, the place where purchases are made,
the location of an inventory of goods and the
location of a bank account. The weight of each
factor for a particular business will depend on the
specific facts and circumstances of the business.
It is important to note that a non-resident vendor
may carry on a business in Canada even if the
vendor does not have a permanent establishment
in Canada. In general, a supply of personal
property or a service, except for certain supplies,
made in Canada by a non-resident vendor not
registered for GST is deemed to be made outside
Canada unless the supply is made in the course
of a business carried on in Canada. However,
this deeming provision does not apply to the
supply of an admission in respect of a place of
amusement, a seminar, an activity or an event
where the non-resident vendor did not acquire
the admission from another person. However,
depending on the specific facts, at the time of
import, the GST will generally have to be paid on
the taxable imported goods or self-assessed by
Canadian residents on imported taxable intangible
personal property and services.
If there is no current requirement, is there any In its 2014 federal budget, the government
anticipated change to that position? announced consultation on the issue of
ensuring the effective collection for sales tax on
e-commerce sales to Canadians made by non-
resident vendors.
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?

Supplies of Is a non-resident supplier of e-services to As for B2C supplies, this will depend on the exact
e-services to business customers located in this country facts and circumstances.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any In its 2014 federal budget, the government
anticipated change to that position? announced consultation on the issue of
ensuring the effective collection for sales tax
on e-commerce sales to Canadians made by
non-resident vendors.
If there is not a requirement for the non- Yes. In general, where a non-resident vendor
resident supplier to register for VAT/GST, are does not charge and collect GST, the recipient
the services subject to VAT/GST withholding in Canada must self-assess GST on imported
by the customer? services if those supplies are not acquired
exclusively in the course of the recipient's
commercial activities.
Where there When did/will that requirement come into The current rules have been in place since the
is a current effect? introduction of GST in Canada.
or future
requirement
for non- What is the applicable annual turnover General rules apply. In general, a vendor that
resident threshold (in local currency) for that makes taxable supplies in Canada must register
suppliers to requirement to apply? for GST if the value of the taxable supplies made
register and/ in Canada or outside Canada by the vendor and
or account any associated entities exceeds 30,000 Canadian
for local VAT/ dollars (CAD) in the last four consecutive quarters
GST or a or in a single quarter.
customer VAT Is simplified or standard registration required? Standard
withholding
requirement: Does the requirement apply to all e-services? A non-resident vendor registered for GST must
charge GST on all its taxable supplies made in
Canada.

China
Supplies of Is a non-resident supplier of e-services to No
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Not applicable
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No. In China’s VAT system, there is no VAT
e-services to business customers located in this country registration requirement for overseas companies.
businesses obliged to register and/or account for local When an overseas company provides a service to
(B2B) VAT/GST on such supplies in this country? a Chinese purchaser, it cannot register as a VAT
taxpayer and pay VAT directly in China. Instead,
the VAT will be collected through the withholding
mechanism.
For digitized services, there is no special
treatment, the above general regulations also
apply.
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- Yes
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into No registration requirement exists.
is a current effect?
or future
requirement
for non- What is the applicable annual turnover No registration or reporting obligation exists.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? No registration requirement exists.
or account
for local VAT/ Does the requirement apply to all e-services? Yes, the VAT withholding requirement applies to
GST or a all e-services.
customer VAT
withholding
requirement:

Colombia
Supplies of Is a non-resident supplier of e-services to No
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Yes, there is a scheduled introduction of such a
anticipated change to that position? requirement
Is an invoice compliant with the VAT/GST law Yes, in principle providers of foreign services
in the customer's country required? would be required to issue invoices.
Supplies of Is a non-resident supplier of e-services to No
e-services to business customers located in this country
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any Yes, there is a scheduled introduction of such a
anticipated change to that position? requirement
If there is not a requirement for the non- Yes, to the extent that the beneficiary of the
resident supplier to register for VAT/GST, are service (Colombian payer) has been designated
the services subject to VAT/GST withholding by the Tax Authority as a withholding agent the
by the customer? beneficiary would apply the VAT withholding tax
(“WHT”). This WHT would operate as a reverse
charge. In the event that the customer is not
a withholding agent, the non-resident vendor
could be required to register under the “ordinary
registration regime”. The withholding would be via
reverse charge.
Where there When did/will that requirement come into 1 July 2018
is a current effect?
or future
requirement
for non- What is the applicable annual turnover In principle no threshold would be applicable.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? The new regulations set forth a simplified
or account registration regime.
for local VAT/
GST or a Does the requirement apply to all e-services? Yes
customer VAT
withholding
requirement:

Croatia
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Croatia.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Croatia from suppliers
or future established in another EU member state.
requirement —— 1 July 2013 for B2C supplies of e-services
for non- to consumers in Croatia from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Cyprus
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Cyprus.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Cyprus from suppliers
or future established in another EU member state.
requirement —— 1 May 2004 for B2C supplies of e-services
for non- to consumers in Cyprus from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Czech Republic
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Czech
(B2C) such supplies in this country? Republic. However, a VAT registration can be
avoided through the use of the Mini One Stop
Shop (MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No for individual consumers.
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Czech Republic from
or future suppliers established in another EU member
requirement state.
for non- —— 1 May 2004 for B2C supplies of e-services to
resident consumers in Czech Republic from suppliers
suppliers to established in a non-EU country.
register and/
or account What is the applicable annual turnover There is no minimum threshold.
for local VAT/ threshold (in local currency) for that
GST or a requirement to apply?
customer VAT Is simplified or standard registration required? Non-resident vendors have the option to register
withholding either in each EU member state where B2C sales
requirement: are made, in which case the registration would
be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Denmark
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Denmark.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Denmark from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Denmark from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Egypt
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to Yes
e-services to business customers located in this country
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
If there is not a requirement for the non- Not applicable
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into 8 September 2016
is a current effect?
or future
requirement
for non- What is the applicable annual turnover 500,000 Egyptian pounds (EGP)
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? It is currently a standard registration. The tax
or account authority has not issued any more detailed
for local VAT/ regulations about the type of registration.
GST or a
customer VAT Does the requirement apply to all e-services? Yes
withholding
requirement:

Finland
Supplies of Is a non-resident supplier of e-services to Yes. There is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Finland.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Finland from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Finland from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

France
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in France.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in France from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in France from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Germany
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Germany.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes, if the customer is a legal person which does
in the customer's country required? not qualify as taxable person.
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Germany from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Germany from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would be
requirement: standard, or, subject to certain conditions, register
in one EU member state under the Mini One Stop
Shop (MOSS), an EU wide simplified registration
(collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Ghana
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to Yes. There is an enacted legislative instrument
e-services to business customers located in this country requiring a non-resident or its agent to register
businesses obliged to register and/or account for local and charge the tax. (Value Added Tax Act, 2013
(B2B) VAT/GST on such supplies in this country? Act 807). In addition, regulation 7 of the Value
Added Tax Regulation, 2016 L.I. 2243 stipulates
that; the Commissioner General may in writing
and subject to satisfactory conditions permit a
non-resident person providing telecommunication
or electronic transactions to register for the VAT,
file returns or account for the tax.
If there is no current requirement, is there any Requirement is already in place.
anticipated change to that position?
If there is not a requirement for the non- Not applicable
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into 1 January 2014
is a current effect?
or future
requirement
for non- What is the applicable annual turnover 120,000 Ghanaian cedi (GHS)
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Standard
or account
for local VAT/ Does the requirement apply to all e-services? Yes
GST or a
customer VAT
withholding
requirement:

Iceland
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No
e-services to business customers located in this country
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into 1 November 2011
is a current effect?
or future
requirement
for non- What is the applicable annual turnover 2 million Icelandic krona (ISK)
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Standard. In addition, non-resident vendors must
or account register via a VAT representative.
for local VAT/
GST or a Does the requirement apply to all e-services? Yes
customer VAT
withholding
requirement:

India
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, reverse charge applies. The requirement for
e-services to business customers located in this country a non-resident supplier to register in India for tax
businesses obliged to register and/or account for local payment is triggered only in the case where the
(B2B) VAT/GST on such supplies in this country? supply of digital services is to a government or a
consumer in India. It is not applicable in the case
of B2B supplies as the receiver of the services
in India will be liable to pay tax under the reverse
charge mechanism.
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for GST on this price
the services subject to VAT/GST withholding in its GST return.
by the customer?

Where there When did/will that requirement come into 1 July 2017
is a current effect?
or future
requirement
for non- What is the applicable annual turnover Under the GST law, a non-resident supplier
resident threshold (in local currency) for that providing digital services to a customer (other
suppliers to requirement to apply? than a registered person) is mandatorily required
register and/ to obtain GST registration in India.
or account Is simplified or standard registration required? Simplified
for local VAT/
GST or a Does the requirement apply to all e-services? No, only to digital services as defined in the law.
customer VAT Online information and database access or
withholding retrieval services is defined as services whose
requirement: delivery is mediated by information technology
over the internet or an electronic network and the
nature of which renders their supply essentially
automated and involving minimal human
intervention and impossible to ensure in the
absence of information technology and includes
electronic services such as,
—— advertising on the internet
—— providing cloud services
—— provision of e-books, movie, music,
software and other intangibles through
telecommunication networks or internet
—— providing data or information, retrievable or
otherwise, to any person in electronic form
through a computer network
—— online supplies of digital content (movies,
television shows, music and the like)
—— digital data storage; and
—— online gaming.

Indonesia
Supplies of Is a non-resident supplier of e-services to No, a non-resident vendor, without a permanent
e-services to consumers located in this country obliged to establishment is not liable to register for VAT in
consumers register and/or account for local VAT/GST on Indonesia. The sale of cross-border electronically
(B2C) such supplies in this country? supplied services to consumers is subject to self-
assessed VAT with the consumer in Indonesia
being required to pay self-assessed VAT to the
State Treasury.
If there is no current requirement, is there any No
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Not applicable
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the customer pays the full price to the
e-services to business customers located in this country supplier, and self-assesses for VAT on this price in
businesses obliged to register and/or account for local its VAT return.
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into No requirement exists.
is a current effect?
or future
requirement
for non- What is the applicable annual turnover No registration or reporting obligation exists.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? No registration is required.
or account
for local VAT/ Does the requirement apply to all e-services? Not applicable
GST or a
customer VAT
withholding
requirement:

Ireland
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Ireland.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No. There is no requirement to issue an
in the customer's country required? invoice for VAT purposes on supplies to private
consumers.
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Ireland from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Ireland from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Isle of Man
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Isle of Man.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Isle of Man from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Isle of Man from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Italy
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Italy.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No, there is no requirement to issue an
in the customer's country required? invoice for VAT purposes on supplies to private
consumers.
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Italy from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services to
for non- consumers in Italy from suppliers established
resident in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Japan
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to It is important to note that Japan Consumption
consumers register and/or account for local VAT/GST on Tax (JCT) law does not provide a precise
(B2C) such supplies in this country? definition of a Business and a Consumer. Rather,
JCT law firstly tries to recognize a business
recipient based on the characteristics of the
services or the terms and conditions of the
service agreement. Specifically, B2B digital
services refer to the services that are normally
consumed by business customers, and then
B2C digital services are recognized as the digital
services other than the B2B digital services.

If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes, although currently there is not yet a formal
in the customer's country required? tax invoicing regime in the context of JCT, a
registered foreign supplier is required to issue
invoices including relevant information (e.g.
the registration number) upon the customers’
request.
Supplies of Is a non-resident supplier of e-services to No, reverse charge applies. It is important to note
e-services to business customers located in this country that JCT law does not provide a precise definition
businesses obliged to register and/or account for local of a Business and a Consumer. Rather, JCT law
(B2B) VAT/GST on such supplies in this country? firstly tries to recognize a business recipient
based on the characteristics of the services
or the terms and conditions of the service
agreement. Specifically, B2B digital services
refer to the services that are normally consumed
by business customers, and then B2C digital
services are recognized as the digital services
other than the B2B digital services.
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for JCT on this price
the services subject to VAT/GST withholding in its JCT return.
by the customer?

Where there When did/will that requirement come into 1 October 2015
is a current effect?
or future
requirement
for non- What is the applicable annual turnover 10 million Japanese yen (JPY) — the foreign
resident threshold (in local currency) for that supplier who does not have a permanent
suppliers to requirement to apply? establishment in Japan is required to register if
register and/ their taxable sales excluding the turnover of the
or account B2B digital services in the base period (generally
for local VAT/ referring to the 2 fiscal years prior to the current
GST or a fiscal year) exceeds JPY10 million. In the case of
customer VAT newly established companies, a foreign supplier
withholding may also be required to file a JCT return and pay
requirement: JCT to the Japanese government if its share capital
or the turnover of the controlling party of the
supplier exceeds a certain prescribed threshold.
Is simplified or standard registration required? Standard, JCT law does not provide for simplified
registration.
Does the requirement apply to all e-services? No, only digital services which is defined as
‘services supplied through telecommunications
lines such as supplies of copyrighted works
through telecommunications lines’.
Examples of digital services indicated by the
Japanese tax authorities are as follows:
—— provision of e-books, digital newspapers,
music, videos, and software (including various
applications such as games) via the internet;
—— services that allow customers to use software
and databases in the cloud;
—— services that provide customers with storage
space to save their electronic data in the
cloud;
—— distribution of advertisements via the internet;
—— Services that allow customers to access
shopping and auction sites on the internet
(e.g., charges for posting goods for sale, etc.);
—— services that allow customers to access
places to sell game software and other
products on the internet;
—— provision via the internet of reservation
websites for accommodation and restaurants
(those who charge for posting on the
website from the businesses that provide
accommodation and operate restaurants);
—— English lessons provided via the internet;
—— consulting services provided continuously via
telephone and emails.

Kenya
Supplies of Is a non-resident supplier of e-services to Yes. They are required to register if they provide
e-services to consumers located in this country obliged to the services to persons who are not registered
consumers register and/or account for local VAT/GST on for VAT.
(B2C) such supplies in this country?
If there is no current requirement, is there any N/A
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No
e-services to business customers located in this country
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No change anticipated
anticipated change to that position?
If there is not a requirement for the non- No. Kenya operates a reverse VAT regime where
resident supplier to register for VAT/GST, are only those customers who make exempt sales
the services subject to VAT/GST withholding are required to account for reverse VAT on
by the customer? imported services.
Where there When did/will that requirement come into 2 September 2013
is a current effect?
or future
requirement
for non- What is the applicable annual turnover 5 million Kenyan shilling (KES)
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? There is no provision for a simplified registration.
or account However, there is a provision for the appointment
for local VAT/ of a local tax representative who is expected to
GST or a account for VAT on behalf of the non-resident
customer VAT person.
withholding
requirement: Does the requirement apply to all e-services? No. The requirement is restricted to the
following e-services when delivered through a
telecommunication network:
a) web hosting
b) remote maintenance of programs and
equipment
c) software and updating of software
d) images, text and information
e) access to databases
f) music, films and games; and
g) radio and television broadcasts.

Lithuania
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Lithuania.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No, there is no requirement to issue an
in the customer's country required? invoice for VAT purposes on supplies to private
consumers.
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Lithuania from suppliers
or future established in another EU member state.
requirement —— 1 May 2004 for B2C supplies of e-services
for non- to consumers in Lithuania from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Luxembourg
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Luxembourg.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, The business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Luxembourg from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Luxembourg from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Malaysia
Supplies of Is a non-resident supplier of e-services to No
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Yes
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any Changes are expected to the requirement for
anticipated change to that position? non-residents suppliers (of services) to register
for GST in Malaysia soon. More details will come,
following the 2018 National Budget announcement
(scheduled for Friday, 27 October 2017).
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for GST on this price
the services subject to VAT/GST withholding in its GST return.
by the customer?
Where there When did/will that requirement come into No requirement exists.
is a current effect?
or future
requirement
for non- What is the applicable annual turnover No registration or reporting obligation exists.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? No registration is required.
or account
for local VAT/ Does the requirement apply to all e-services? Not applicable
GST or a
customer VAT
withholding
requirement:

Malta
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Malta.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes, unless the services are being supplied under
in the customer's country required? MOSS.
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Malta from suppliers
or future established in another EU member state.
requirement —— 1 May 2004 for B2C supplies of e-services
for non- to consumers in Malta from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Mexico
Supplies of Is a non-resident supplier of e-services to No
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No, however, while there is no formal obligation
in the customer's country required? for the non-resident supplier to issue an invoice,
if the Mexican resident asks for an invoice such
document should comply with some simplified
invoice requirements (mainly information), in
order that the Mexican resident could deduct the
cost of such digital services for Corporate Income
Tax purposes (in a B2B context).
Supplies of Is a non-resident supplier of e-services to No
e-services to business customers located in this country
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into No requirement exists.
is a current effect?
or future
requirement
for non- What is the applicable annual turnover No registration or reporting obligation exists.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? No registration is required.
or account
for local VAT/ Does the requirement apply to all e-services? No registration requirement exists.
GST or a
customer VAT
withholding
requirement:

Netherlands
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Netherlands.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Netherlands from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Netherlands from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

New Zealand
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any The requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, B2B supplies of remote services are exempt
e-services to business customers located in this country as long as the supplier obtains confirmation of
businesses obliged to register and/or account for local the customer's business status.
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any Not required, but a non-resident supplier can opt
anticipated change to that position? in to register and charge GST.
If there is not a requirement for the non- No
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into 1 October 2016
is a current effect?
or future
requirement
for non- What is the applicable annual turnover 60,000 New Zealand dollars (NZD)
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Simplified
or account
for local VAT/ Does the requirement apply to all e-services? Yes, all electronic services are included, but
GST or a the requirements are broader than that — they
customer VAT include all “remote services”. The definition of
withholding a "remote service" in New Zealand refers to a
requirement: service where there is no necessary connection
between the location of the supplier and the
location of the recipient at the time of service.
Where a service can be provided via electronic
means, it would indicate that there is no
necessary connection between the locations of
the supplier and the recipient. As such, prima
facie, those services come within the scope of
the remote services rule in New Zealand, but
non-electronic remote services e.g. legal advice
do also.

Norway
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into 1 July 2011
is a current effect?
or future
requirement
for non- What is the applicable annual turnover 50,000 Norwegian krone (NOK)
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Optional. The non-resident vendor can choose
or account between simplified or standard registration.
for local VAT/
GST or a Does the requirement apply to all e-services? No, only electronic services as defined in the
customer VAT Norwegian VAT law. This means services capable
withholding of delivery from a remote location which are
requirement: supplied over the internet or electronic network
and which cannot be obtained without the use of
information technology, and where delivery of the
services is essentially automated.

Poland
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Poland.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Poland from suppliers
or future established in another EU member state.
requirement —— 1 May 2004 for B2C supplies of e-services
for non- to consumers in Poland from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Portugal
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Portugal.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Portugal from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Portugal from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Romania
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Romania.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Romania from suppliers
or future established in another EU member state.
requirement —— 1 May 2007 for B2C supplies of e-services
for non- to consumers in Romania from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Russia
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No
e-services to business customers located in this country
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- Yes and withheld VAT is recoverable by the
resident supplier to register for VAT/GST, are customer if necessary conditions of VAT recovery
the services subject to VAT/GST withholding are met.
by the customer?
Where there When did/will that requirement come into 1 January 2017
is a current effect?
or future
requirement
for non- What is the applicable annual turnover There is no minimum threshold
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Simplified, non-resident vendors that supply
or account electronically supplied services to Russian
for local VAT/ individuals or intermediary companies with
GST or a respect to such services are liable to become tax
customer VAT registered in Russia and pay VAT. Non-resident
withholding vendors have no right to recover input VAT unless
requirement: they create a presence in Russia.
Does the requirement apply to all e-services? Yes, similar requirements apply irrespective of the
type of electronic service.

Serbia
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law There is no obligation to issue a VAT invoice for
in the customer's country required? supplies to individuals not registered for VAT.
Supplies of Is a non-resident supplier of e-services to No, a foreign entity which provides taxable
e-services to business customers located in this country supplies of goods and services in Serbia
businesses obliged to register and/or account for local exclusively to VAT payers (i.e. entities registered
(B2B) VAT/GST on such supplies in this country? for VAT in Serbia) or public bodies not considered
taxable persons is not obliged to appoint a tax
representative and register for VAT in Serbia.
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into 1 January 2017
is a current effect?
or future
requirement
for non- What is the applicable annual turnover There is no minimum threshold.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Standard registration. Foreign entities supplying
or account services in Serbia to entities which are not
for local VAT/ registered for VAT, are required to register for
GST or a VAT via the appointment of VAT proxy. The VAT
customer VAT proxy, in the name and on behalf of the foreign
withholding entity, performs all activities related to fulfilment
requirement: of obligations and performing rights of the foreign
entity that it has as a VAT payer (issuance of
invoices, submissions of VAT returns, payment
of VAT to the tax authorities, etc.). The VAT
proxy is jointly liable for VAT obligations of the
represented foreign entity.

(Continued Does the requirement apply to all e-services? Yes, the VAT regulations provide the following
from the exclusive (not indicative) list of services that are
previous considered as electronically provided services:
page) 1. Supply of web pages, storage and
Where there maintenance of web pages;
is a current 2. Supply of programs and their updating,
or future remote maintenance of programs and
requirement computer equipment;
for non-
3. Supply of pictures, texts and information
resident
and enabling database access, as well as
suppliers to
database archiving;
register and/
or account 4. Supply of audio and video records, as well as
for local VAT/ supply of games;
GST or a 5. Supply of political, cultural, art, sports,
customer VAT science, educational and entertainment
withholding programs and events during or after their
requirement: shooting;
6. Services in the area of long distance learning.

Singapore
Supplies of Is a non-resident supplier of e-services to No
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any As part of the budget for 2017, the Singapore
anticipated change to that position? government announced that it is looking at the
growth of digital transactions and cross border
trade and considering the GST impacts to ensure
both domestic and foreign businesses are
operating on an even playing field. Consultations
were released in May 2017.
Is an invoice compliant with the VAT/GST law Not applicable, this is being considered as part of
in the customer's country required? the ongoing consultation.
Supplies of Is a non-resident supplier of e-services to No
e-services to business customers located in this country
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any A consultation was released in May 2017 for
anticipated change to that position? the proposed introduction of a reverse charge
mechanism for B2B imported services.
If there is not a requirement for the non- No
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into No requirement exists.
is a current effect?
or future
requirement
for non- What is the applicable annual turnover No registration or reporting obligation exists.
resident threshold (in local currency) for that This is being considered as part of the ongoing
suppliers to requirement to apply? consultation.
register and/ Is simplified or standard registration required? No registration is required. This is being
or account considered as part of the ongoing consultation.
for local VAT/
GST or a Does the requirement apply to all e-services? Not applicable, this is being considered as part of
customer VAT the ongoing consultation.
withholding
requirement:

Slovakia
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Slovakia.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Slovakia from suppliers
or future established in another EU member state.
requirement —— 1 May 2004 for B2C supplies of e-services
for non- to consumers in Slovakia from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Slovenia
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Slovenia.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Slovenia from suppliers
or future established in another EU member state.
requirement —— 1 May 2004 for B2C supplies of e-services
for non- to consumers in Slovenia from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

South Africa
Supplies of Is a non-resident supplier of e-services to Yes, (see additional comments below).
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes, an electronic services supplier must issue
in the customer's country required? a tax invoice for a supply of electronic services
containing minimum information.
Supplies of Is a non-resident supplier of e-services to Yes, for both B2C and B2B supplies, the South
e-services to business customers located in this country African VAT Act requires a person to register for
businesses obliged to register and/or account for local VAT if the person carries on an enterprise and in
(B2B) VAT/GST on such supplies in this country? the course of furtherance thereof, makes taxable
supplies exceeding a threshold (of ZAR50,000 in
the case of electronic services).
The definition of an enterprise in the VAT Act
includes:
The supply of electronic services by a person
from a place outside South Africa where at least
two of the following circumstances are present:
—— The recipient of the electronic services is a
resident of South Africa;
—— Any payment to that person in respect of
such electronic services originates from a
bank registered or authorized in terms of the
Banks Act; and
—— The recipient of those electronic services has
a business address, residential address or
postal address in South Africa.
Electronic services as envisaged above, are set
out in a separate regulation.

If there is no current requirement, is there any Requirement is already in place.

anticipated change to that position?
If there is not a requirement for the non- Not applicable
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?

Where there When did/will that requirement come into 1 June 2014
is a current effect?
or future
requirement
for non- What is the applicable annual turnover 50,000 South African rand (ZAR)
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Standard. Deductions of input tax would be
or account limited to instances where the non-resident
for local VAT/ vendor was charged South African VAT at
GST or a 14 percent on the acquisition of goods or
customer VAT services for purposes of making electronic
withholding services supplied to a recipient in South Africa.
requirement:
Does the requirement apply to all e-services? No, "electronic services" which are subject
to these VAT rules are specifically listed in
Government Notice R221. Other forms of
e-services do not fall within these rules.

South Korea
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any The requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into 1 July 2015
is a current effect?
or future
requirement
for non- What is the applicable annual turnover There is no minimum threshold.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Simplified
or account
for local VAT/ Does the requirement apply to all e-services? No
GST or a
customer VAT
withholding
requirement:

Spain
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Spain.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Spain from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Spain from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Sweden
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in Sweden.
(B2C) such supplies in this country? However, a VAT registration can be avoided
through the use of the Mini One Stop Shop
(MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No, there is no requirement to issue an
in the customer's country required? invoice for VAT purposes on supplies to private
consumers.
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in Sweden from suppliers
or future established in another EU member state.
requirement —— 1 July 2003 for B2C supplies of e-services
for non- to consumers in Sweden from suppliers
resident established in a non-EU country.
suppliers to
register and/ What is the applicable annual turnover There is no minimum threshold.
or account threshold (in local currency) for that
for local VAT/ requirement to apply?
GST or a Is simplified or standard registration required? Non-resident vendors have the option to register
customer VAT either in each EU member state where B2C sales
withholding are made, in which case the registration would
requirement: be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

Switzerland and Liechtenstein

Supplies of Is a non-resident supplier of e-services to Yes, subject to threshold as described below.
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No
e-services to business customers located in this country
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into 1 January 2010
is a current effect?
or future
requirement
for non- What is the applicable annual turnover Prior to 1 January 2018, the threshold for
resident threshold (in local currency) for that non-resident sellers of e-services to non-VAT
suppliers to requirement to apply? registered persons (B2C) to register for and
register and/ charge Swiss VAT is turnover of more than
or account 100,000 Swiss francs (CHF) from sales to
for local VAT/ customers in Switzerland. From 1 January 2018,
GST or a threshold will be CHF100,000 of worldwide
customer VAT turnover from sales of e-services, with at
withholding least CHF1 of sales to customers located in
requirement: Switzerland.
Is simplified or standard registration required? Standard
Does the requirement apply to all e-services? Yes

Tanzania
Supplies of Is a non-resident supplier of e-services to Yes
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law Yes
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to Yes
e-services to business customers located in this country
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any Requirement is already in place.
anticipated change to that position?
If there is not a requirement for the non- Not applicable
resident supplier to register for VAT/GST, are
the services subject to VAT/GST withholding
by the customer?
Where there When did/will that requirement come into 1 July 2015
is a current effect?
or future
requirement
for non- What is the applicable annual turnover There is no minimum threshold.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Standard, the non-resident must appoint a fiscal
or account representative.
for local VAT/
GST or a Does the requirement apply to all e-services? Yes. “Electronic services” means any of the
customer VAT following services provided or delivered through a
withholding telecommunications network:
requirement: 1. websites, web-hosting, or remote
maintenance of programmes and equipment
2. software and the updating thereof
3. images, text, and information
4. access to databases
5. self-education packages
6. music, films, and games, including gaming
activities
7. political, cultural, artistic, sporting, scientific,
and other broadcasts and events including
broadcast television.

Thailand
Supplies of Is a non-resident supplier of e-services to No, reverse charge applies. However, practically,
e-services to consumers located in this country obliged to there is no mechanism to force individuals to
consumers register and/or account for local VAT/GST on collect and report VAT.
(B2C) such supplies in this country?
If there is no current requirement, is there any The timing of when the new law will become
anticipated change to that position? effective is unknown at this stage.
It is not clear whether the draft legislation on
e-commerce, especially for VAT implications, will
apply to B2C transactions only.
Is an invoice compliant with the VAT/GST law Yes, however, it is unclear whether this
in the customer's country required? requirement will be amended or simplified under
the new law.
Supplies of Is a non-resident supplier of e-services to No, reverse charge applies. Currently, Thailand
e-services to business customers located in this country does not require a digital service provider
businesses obliged to register and/or account for local who is residing outside of Thailand and has no
(B2B) VAT/GST on such supplies in this country? permanent establishment in Thailand to register
for VAT. Thus the reverse charge applies.
If there is no current requirement, is there any There is a draft legislative proposal to introduce
anticipated change to that position? such a requirement.
Under the draft legislation, a foreign company
that sells intangible goods or renders services
through electronic media to a non-VAT registered
person in Thailand will be required to register for
VAT and will be subject to VAT on the Thai sales it
concludes. It is unclear whether this will be limited
to B2C or will extend to B2B, and if so, what the
consequential changes will be in relation to the
currently applicable reverse charge mechanism.
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into No requirement exists currently. The timing
is a current effect? of when the new law will become effective is
or future unknown at this stage.
requirement
for non- What is the applicable annual turnover THB1,800,000 — Within 30 days after VAT
resident threshold (in local currency) for that revenue reaches this level. The same threshold is
suppliers to requirement to apply? proposed under the draft legislation.
register and/ Is simplified or standard registration required? It is unclear whether the standard registration
or account requirements will be amended or simplified
for local VAT/ under the new law. Current VAT registration
GST or a requirements lead to creation of an income
customer VAT tax permanent establishment and various legal
withholding issues.
requirement:
Does the requirement apply to all e-services? No, under the existing legislation.
Yes, under the draft legislation.

Turkey
Supplies of Is a non-resident supplier of e-services to No
e-services to consumers located in this country obliged to
consumers register and/or account for local VAT/GST on
(B2C) such supplies in this country?
If there is no current requirement, is there any Currently the Ministry of Finance is investigating
anticipated change to that position? non-resident vendors' revenue generation in
Turkey (e-commerce in Turkey such as pop-up
ads etc.) and they are sending formal letters
to companies' headquarters asking them to
provide additional information. The Ministry of
Finance's main aim is to subject any revenues to
tax which are earned in Turkey. Double taxation
engagements will need to be evaluated as well.
This is currently a hot topic in Turkey.
Is an invoice compliant with the VAT/GST law No
in the customer's country required?
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into Not applicable.
is a current effect?
or future
requirement
for non- What is the applicable annual turnover Not applicable.
resident threshold (in local currency) for that
suppliers to requirement to apply?
register and/ Is simplified or standard registration required? Not applicable.
or account
for local VAT/ Does the requirement apply to all e-services? Not applicable.
GST or a
customer VAT
withholding
requirement:

United Kingdom
Supplies of Is a non-resident supplier of e-services to Yes, there is an obligation for non-resident
e-services to consumers located in this country obliged to suppliers to charge VAT on B2C supplies of
consumers register and/or account for local VAT/GST on e-services to a consumer located in United
(B2C) such supplies in this country? Kingdom. However, a VAT registration can be
avoided through the use of the Mini One Stop
Shop (MOSS) in another EU member state.
If there is no current requirement, is there any Not applicable, requirement is already in place.
anticipated change to that position?
Is an invoice compliant with the VAT/GST law No, there is no requirement to issue an
in the customer's country required? invoice for VAT purposes on supplies to private
consumers.
Supplies of Is a non-resident supplier of e-services to No, the business customer must self-assess for
e-services to business customers located in this country VAT in its VAT return on a reverse charge basis.
businesses obliged to register and/or account for local
(B2B) VAT/GST on such supplies in this country?
If there is no current requirement, is there any No
anticipated change to that position?
If there is not a requirement for the non- No, the customer pays the full price to the
resident supplier to register for VAT/GST, are supplier, and self-assesses for VAT on this price in
the services subject to VAT/GST withholding its VAT return.
by the customer?
Where there When did/will that requirement come into —— 1 January 2015 for B2C supplies of e-services
is a current effect? to consumers in United Kingdom from
or future suppliers established in another EU member
requirement state.
for non- —— 1 July 2003 for B2C supplies of e-services to
resident consumers United Kingdom from suppliers
suppliers to established in a non-EU country.
register and/
or account What is the applicable annual turnover There is no minimum threshold
for local VAT/ threshold (in local currency) for that
GST or a requirement to apply?
customer VAT Is simplified or standard registration required? Non-resident vendors have the option to register
withholding either in each EU member state where B2C sales
requirement: are made, in which case the registration would
be standard, or, subject to certain conditions,
register in one EU member state under the Mini
One Stop Shop (MOSS), an EU wide simplified
registration (collection only).
Does the requirement apply to all e-services? Yes, as defined under EU VAT law. Under EU
VAT law, electronically supplied services mean
services delivered over the internet or an
electronic network and the nature of which
renders their supply essentially automated
and involving minimum human intervention,
and impossible to ensure in the absence of
information technology. Similar VAT requirements
apply in respect of telecommunication and
broadcasting services.

For more information on KPMG’s Global Indirect

Tax practice and access to thought leadership,
please visit: kpmg.com/indirecttax

kpmg.com
kpmg.com/indirecttax

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to
provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in
the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

© 2017 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG
International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm
vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.

The KPMG name and logo are registered trademarks or trademarks of KPMG International.

Designed by Evalueserve.
Publication name: VAT/GST treatment of cross-border services: 2017 survey
Publication number: 134952-G
Publication date: November 2017

Taxing E-Commerce Transactions: A Global Perspective: April 2016
No ratings yet
Taxing E-Commerce Transactions: A Global Perspective: April 2016
11 pages
Taxes in An E-Commerce Generation: David R. Agrawal William F. Fox
No ratings yet
Taxes in An E-Commerce Generation: David R. Agrawal William F. Fox
26 pages
International Taxation Book Publication (1)
No ratings yet
International Taxation Book Publication (1)
10 pages
Taxation International Taxation E-Commerce Issues in Cyber Space
No ratings yet
Taxation International Taxation E-Commerce Issues in Cyber Space
73 pages
Reaction Paper
No ratings yet
Reaction Paper
10 pages
Tax Related Thesis Topics
100% (3)
Tax Related Thesis Topics
8 pages
Sell Us
No ratings yet
Sell Us
15 pages
Kunal Keshri ITLR
No ratings yet
Kunal Keshri ITLR
16 pages
International Indirect Tax Guide 2016
No ratings yet
International Indirect Tax Guide 2016
384 pages
(Cambridge Tax Law Series) Craig Elliffe - Taxing the Digital Economy_ Theory, Policy and Practice-Cambridge University Press (2021)
No ratings yet
(Cambridge Tax Law Series) Craig Elliffe - Taxing the Digital Economy_ Theory, Policy and Practice-Cambridge University Press (2021)
356 pages
Taxation of Electronic Commerce: A Developing Problem
No ratings yet
Taxation of Electronic Commerce: A Developing Problem
17 pages
VAT and The Internet The Application of Consumption Taxes To e Commerce Transactions
No ratings yet
VAT and The Internet The Application of Consumption Taxes To e Commerce Transactions
30 pages
Advanced Issues In International And European Tax Law Christiana Hji Panayi download
100% (1)
Advanced Issues In International And European Tax Law Christiana Hji Panayi download
80 pages
Advanced Issues In International And European Tax Law Christiana Hji Panayi pdf download
No ratings yet
Advanced Issues In International And European Tax Law Christiana Hji Panayi pdf download
76 pages
3.7 Protto Manual CPTI - EN
No ratings yet
3.7 Protto Manual CPTI - EN
28 pages
ssrn_id3757889_code1240973
No ratings yet
ssrn_id3757889_code1240973
25 pages
Taxation of e Commerce
100% (1)
Taxation of e Commerce
6 pages
Explanation of the role of taxes in government revenue
No ratings yet
Explanation of the role of taxes in government revenue
6 pages
Project on 'GOODS AND SERVICE TAX IN INDIA'
No ratings yet
Project on 'GOODS AND SERVICE TAX IN INDIA'
67 pages
SSRN Id3309920
No ratings yet
SSRN Id3309920
10 pages
Wengs Taxes
No ratings yet
Wengs Taxes
10 pages
Emerging E-Business Models: Indirect Tax Implications
No ratings yet
Emerging E-Business Models: Indirect Tax Implications
29 pages
Indirect Tax Guide Estados Unidos 2016
No ratings yet
Indirect Tax Guide Estados Unidos 2016
3 pages
"Transaction-based Tax Evasion on Chinese E-commerce Platforms: Compliance Difficulties for Three Types of Taxes, VAT Reform, and New Winners"
No ratings yet
"Transaction-based Tax Evasion on Chinese E-commerce Platforms: Compliance Difficulties for Three Types of Taxes, VAT Reform, and New Winners"
19 pages
Millennian S. Tax Assignment
No ratings yet
Millennian S. Tax Assignment
9 pages
USALaw Taxation
No ratings yet
USALaw Taxation
4 pages
Economic Challenges in India - Before and After GST
No ratings yet
Economic Challenges in India - Before and After GST
19 pages
Vat Global
No ratings yet
Vat Global
32 pages
International Business Environment: Associate Professor Radu Mușetescu, PHD Radu - Musetescu@Rei - Ase
No ratings yet
International Business Environment: Associate Professor Radu Mușetescu, PHD Radu - Musetescu@Rei - Ase
29 pages
INTERNATIONAL TAX CHALLENGES AND INITIATIVES
No ratings yet
INTERNATIONAL TAX CHALLENGES AND INITIATIVES
24 pages
4-Taxation of Income From E-Commerce in Ethiopia
No ratings yet
4-Taxation of Income From E-Commerce in Ethiopia
27 pages
Eurodad - Hidden Profits The EU's Role in Supporting An Unjust Global Tax System PDF
No ratings yet
Eurodad - Hidden Profits The EU's Role in Supporting An Unjust Global Tax System PDF
112 pages
India GST For Beginners by Jayaram Hiregange, Deepak Rao
No ratings yet
India GST For Beginners by Jayaram Hiregange, Deepak Rao
108 pages
11a -International Taxation-Introduction
No ratings yet
11a -International Taxation-Introduction
53 pages
Indirect Tax 2013
No ratings yet
Indirect Tax 2013
120 pages
The Quickbooks User'S Guide To Sales and Use Tax: How This Guide May Help You
No ratings yet
The Quickbooks User'S Guide To Sales and Use Tax: How This Guide May Help You
26 pages
Taxation of E-Commerce Transactions
No ratings yet
Taxation of E-Commerce Transactions
16 pages
Descriptive Study On GST & Its Worldwide Implications
No ratings yet
Descriptive Study On GST & Its Worldwide Implications
15 pages
20170508 BNA Paper Blockchain_TPCustoms_(Final)
No ratings yet
20170508 BNA Paper Blockchain_TPCustoms_(Final)
17 pages
01asakawa Presentation Slides - Editedforhandout
No ratings yet
01asakawa Presentation Slides - Editedforhandout
111 pages
Guide to Vat Gst Sut in the Americas 2018 Indirect Tax Guidance of 21 Countries in the Americas
No ratings yet
Guide to Vat Gst Sut in the Americas 2018 Indirect Tax Guidance of 21 Countries in the Americas
209 pages
MGMT 3046 9781484315224-ch004
No ratings yet
MGMT 3046 9781484315224-ch004
22 pages
A Guide to Vat Gst Sut in the Americas 2020
No ratings yet
A Guide to Vat Gst Sut in the Americas 2020
197 pages
HAARISH PROJECT
No ratings yet
HAARISH PROJECT
32 pages
Research Article17
No ratings yet
Research Article17
12 pages
Corporate and Indirect Tax Survey 2009 (KPMG 2009)
No ratings yet
Corporate and Indirect Tax Survey 2009 (KPMG 2009)
56 pages
Tax international
No ratings yet
Tax international
129 pages
202210Utamura San
No ratings yet
202210Utamura San
21 pages
SSRN 25092018
No ratings yet
SSRN 25092018
13 pages
Fifty Shades of Tax Dodging The Eu S Role in Supporting An Unjust Global Tax System
No ratings yet
Fifty Shades of Tax Dodging The Eu S Role in Supporting An Unjust Global Tax System
176 pages
Calculate Tax
No ratings yet
Calculate Tax
17 pages
GST (Goods & Service Tax: Submitted by Nikita Sawant 44 Aditya Kadam 22
No ratings yet
GST (Goods & Service Tax: Submitted by Nikita Sawant 44 Aditya Kadam 22
19 pages
International Vatgst Guidelines Oecd instant download
No ratings yet
International Vatgst Guidelines Oecd instant download
43 pages
BrianJArnold 2019 CHAPTER1Introduction InternationalTaxPrime
No ratings yet
BrianJArnold 2019 CHAPTER1Introduction InternationalTaxPrime
16 pages
Taxation Aspects of International E-Commerce: Ewelina Badura
No ratings yet
Taxation Aspects of International E-Commerce: Ewelina Badura
9 pages
1international Organizations Active in The Field of International Tax Law
No ratings yet
1international Organizations Active in The Field of International Tax Law
3 pages
6180A - STLR FRC User Guide HA033668 Issue 3
No ratings yet
6180A - STLR FRC User Guide HA033668 Issue 3
50 pages
WATROD or FIREBAR Heaters User Manual
No ratings yet
WATROD or FIREBAR Heaters User Manual
18 pages
FICS 11 BA HR150087ENG Part1
100% (1)
FICS 11 BA HR150087ENG Part1
13 pages
Versadac™ User Guide (HA031352ENG Issue 3)
No ratings yet
Versadac™ User Guide (HA031352ENG Issue 3)
202 pages
760 Comms Handbook
No ratings yet
760 Comms Handbook
25 pages
Real World Problems of Quadratic
No ratings yet
Real World Problems of Quadratic
10 pages
HA030554 Nanodac Recorder - Controller User Guide (HA030554 Issue 16)
No ratings yet
HA030554 Nanodac Recorder - Controller User Guide (HA030554 Issue 16)
458 pages
NWT Barton Broad
No ratings yet
NWT Barton Broad
1 page
BMW Tyres
No ratings yet
BMW Tyres
22 pages
Country Walks Leaflet For Web
No ratings yet
Country Walks Leaflet For Web
2 pages
Atlas Copco (India) Limited: Notice
No ratings yet
Atlas Copco (India) Limited: Notice
12 pages
The Fundamental Powers of The State
No ratings yet
The Fundamental Powers of The State
2 pages
Establishing A Student
No ratings yet
Establishing A Student
223 pages
Smart Cities Envisioned by MoUD
No ratings yet
Smart Cities Envisioned by MoUD
3 pages
1694686624the Economist at 175 - Reinventing Liberalism in 21st Century
No ratings yet
1694686624the Economist at 175 - Reinventing Liberalism in 21st Century
29 pages
Chris Quinn 2011 State of The City
No ratings yet
Chris Quinn 2011 State of The City
11 pages
Business Tax - VAT
No ratings yet
Business Tax - VAT
165 pages
Peachtree Exercise Part 1
90% (10)
Peachtree Exercise Part 1
6 pages
Punjab Excise and Property Tax Law
No ratings yet
Punjab Excise and Property Tax Law
4 pages
Motilal Oswal Q4 Investor Presentation
No ratings yet
Motilal Oswal Q4 Investor Presentation
70 pages
Advik Shipper Packet- Updated-2024-2025 4
No ratings yet
Advik Shipper Packet- Updated-2024-2025 4
11 pages
Train Law
No ratings yet
Train Law
2 pages
FINA 5120 - Fall (1) 2022 - Session 4 (With Answers) - Capital Budgeting - 26aug22
No ratings yet
FINA 5120 - Fall (1) 2022 - Session 4 (With Answers) - Capital Budgeting - 26aug22
69 pages
Carlos Sempat Assadourian - The Colonial Economy. The Transfer of The European System of Production To New Spain
No ratings yet
Carlos Sempat Assadourian - The Colonial Economy. The Transfer of The European System of Production To New Spain
15 pages
Fee Receipt - 1003447903 - 26-11-2024 13 - 38 - 04
No ratings yet
Fee Receipt - 1003447903 - 26-11-2024 13 - 38 - 04
1 page
Pro-Forma Income Statement & Percentage of Sales For Year 2020
No ratings yet
Pro-Forma Income Statement & Percentage of Sales For Year 2020
9 pages
Capital Gains Long and Short Term
No ratings yet
Capital Gains Long and Short Term
2 pages
Exclusion of Gross Income
No ratings yet
Exclusion of Gross Income
14 pages
HDP 2674
No ratings yet
HDP 2674
6 pages
Set Off Complete Notes 29-5-24
No ratings yet
Set Off Complete Notes 29-5-24
22 pages
Microeconomics Notes
No ratings yet
Microeconomics Notes
53 pages
Portugal Geography History Encyclopedia Britannica 01
No ratings yet
Portugal Geography History Encyclopedia Britannica 01
27 pages
Direct Taxation PDF
100% (1)
Direct Taxation PDF
396 pages
Business Tax Chapter 8 Reviewer
100% (1)
Business Tax Chapter 8 Reviewer
5 pages
ITC Class Notes - InTER - CA Amit Mahajan
No ratings yet
ITC Class Notes - InTER - CA Amit Mahajan
18 pages
Mayors Statement 2012 2013 Full Budget Estimate
No ratings yet
Mayors Statement 2012 2013 Full Budget Estimate
37 pages
Tax MCQ
71% (7)
Tax MCQ
8 pages
Kim Gilbert 2018 PDF
50% (2)
Kim Gilbert 2018 PDF
25 pages
Title: Batangas City v. Pilipinas Shell Petroleum Corp. G.R. No. 187631 Date: July 8. 2015 Ponente: Peralta, J
No ratings yet
Title: Batangas City v. Pilipinas Shell Petroleum Corp. G.R. No. 187631 Date: July 8. 2015 Ponente: Peralta, J
2 pages
Tax Evasion and Tax Havens since the Nineteenth Century Sébastien Guex - Download the full ebook now for a seamless reading experience
No ratings yet
Tax Evasion and Tax Havens since the Nineteenth Century Sébastien Guex - Download the full ebook now for a seamless reading experience
53 pages

Uploaded by

Uploaded by

VAT/GST

VAT/GST and the digital

While most jurisdictions have not issued guidance on this Conclusion

VAT/GST and cross-border

Methodology and Development (OECD) and the G20 in response to the

Summary of key findings

Andorra Yes Not applicable — Requirement Yes No No

Australia Yes Not applicable — Requirement No No No

Belarus No There is a scheduled No No No

Bulgaria Yes Not applicable — Requirement Yes No No

Colombia No There is a scheduled Yes No There is a scheduled

Cyprus Yes Not applicable — Requirement Yes No No

Czech Republic Yes Not applicable — Requirement No No No

Denmark Yes Not applicable — Requirement Yes No No

Finland Yes Not applicable — Requirement Yes No No

France Yes Not applicable — Requirement No No No

Germany Yes Not applicable — Requirement Yes No No

Note: See page 26 for footnotes.

Australia No 1 July 2017 USD60,043 Optional Yes

Belarus Reverse charge 1 January 2018 Nil Optional No (footnote 6)

Colombia Reverse charge 1 July 2018 Nil Simplified Yes

Egypt Not applicable 8 September 2016 USD28,323 Standard Yes

Note: See page 26 for footnotes.

Summary of key findings

Ghana Yes Not applicable — Requirement Yes Yes Requirement is already in

Iceland Yes Not applicable — Requirement Yes No No

India Yes Not applicable — Requirement Yes No No

Indonesia No No Not applicable No No

Ireland Yes Not applicable — Requirement No No No

Isle of Man Yes Not applicable — Requirement No No No

Italy Yes Not applicable — Requirement No No No

Japan Yes Not applicable — Requirement Yes No No

Kenya Yes Not applicable — Requirement Yes No No

Lithuania Yes Not applicable — Requirement No No No

Luxembourg Yes Not applicable — Requirement Yes No No

Malaysia No Yes Yes No Yes

Malta Yes Not applicable — Requirement Yes No No

Mexico No No Not applicable No No

Netherlands Yes Not applicable — Requirement No No No

New Zealand Yes Not applicable — Requirement No No No

Norway Yes Not applicable — Requirement No No No

Poland Yes Not applicable — Requirement Yes No No

Portugal Yes Not applicable — Requirement Yes No No

Note: See page 26 for footnotes.

Iceland Reverse charge 1 November 2011 USD18,692 Standard Yes

India Reverse charge 1 July 2017 Nil Simplified No

Japan Reverse charge 1 October 2015 USD90,482 Standard No

Kenya Reverse charge 2 September 2013 KES5 million Standard No

Mexico No Not applicable Not applicable No registration is required Not applicable

New Zealand No 1 October 2016 USD43,530 Simplified Yes

Norway Reverse charge 1 July 2011 USD6,341 Optional No (footnote 6)

Note: See page 26 for footnotes.

Summary of key findings

Romania Yes Not applicable — Requirement Yes No No

Russia Yes Not applicable — Requirement No No No

Serbia Yes Not applicable — Requirement No No No

Singapore No There is a general proposal or Not applicable No There is a general proposal or

Slovenia Yes Not applicable — Requirement Yes No No

South Korea Yes Not applicable — Requirement No No No

Spain Yes Not applicable — Requirement Yes No No

Sweden Yes Not applicable — Requirement No No No

Switzerland and Yes Not applicable — Requirement Yes No No

Tanzania Yes Not applicable — Requirement Yes Yes Requirement is already in

Thailand No There is a draft legislative Yes No A draft legislative proposal to

United Kingdom Yes Not applicable — Requirement No No No

Russia VAT withholding 1 January 2017 Nil Simplified Yes

Serbia No 1 January 2017 Nil Standard Yes

South Africa Not applicable 1 June 2014 USD3,802 Standard No

South Korea Reverse charge 1 July 2015 Nil Simplified No

Switzerland and Reverse charge 1 January 2010 USD103,685 Standard No

If there is no current requirement, is there any Requirement is already in place.

Switzerland and Liechtenstein

For more information on KPMG’s Global Indirect

You might also like