Pub Date : 2014-10-15DOI: 10.5235/20488432.3.2.115
J. Harmse
{"title":"Value-added tax consequences for foreign suppliers of electronic services into South Africa","authors":"J. Harmse","doi":"10.5235/20488432.3.2.115","DOIUrl":"https://doi.org/10.5235/20488432.3.2.115","url":null,"abstract":"","PeriodicalId":114680,"journal":{"name":"World Journal of VAT/GST Law","volume":"7 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2014-10-15","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"116705551","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2014-06-27DOI: 10.5235/20488432.3.2.101
Yimin Kou, Qiguang Zhou
Arguably the biggest change in China’s tax law in recent years is the reform of its turnover tax regime (‘VAT Pilot’), which will result in the merging of value-added tax (‘VAT’) and business tax (‘BT’) into a single VAT. With the advent of this VAT Pilot there are hot issues facing China, such as the integrity of the supply chain, the place of supply of services and financial leasing. Among these issues, VAT on services in the field of international freight forwarding and international shipping is worthy of close attention.In this article, the authors will share their insights into how the VAT Pilot impacts the international freight forwarding industry and the international shipping industry in China.
{"title":"Impact of the Chinese VAT pilot on the international freight forwarding industry and the international shipping industry","authors":"Yimin Kou, Qiguang Zhou","doi":"10.5235/20488432.3.2.101","DOIUrl":"https://doi.org/10.5235/20488432.3.2.101","url":null,"abstract":"Arguably the biggest change in China’s tax law in recent years is the reform of its turnover tax regime (‘VAT Pilot’), which will result in the merging of value-added tax (‘VAT’) and business tax (‘BT’) into a single VAT. With the advent of this VAT Pilot there are hot issues facing China, such as the integrity of the supply chain, the place of supply of services and financial leasing. Among these issues, VAT on services in the field of international freight forwarding and international shipping is worthy of close attention.In this article, the authors will share their insights into how the VAT Pilot impacts the international freight forwarding industry and the international shipping industry in China.","PeriodicalId":114680,"journal":{"name":"World Journal of VAT/GST Law","volume":"18 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2014-06-27","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122638688","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
{"title":"Taxing Global Digital Commerce by Arthur Cockfield, Walter Hellerstein, Rebecca Millar and Christophe Waerzeggers","authors":"Pernilla Rendahl","doi":"10.5235/20488432.3.1.65","DOIUrl":"https://doi.org/10.5235/20488432.3.1.65","url":null,"abstract":"","PeriodicalId":114680,"journal":{"name":"World Journal of VAT/GST Law","volume":"10 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2014-05-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"115506389","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
{"title":"ECJ rejects bank's computation of the deductible proportion of input VAT in relation to turnover carried out by its branches located in other Member States or third countries","authors":"Yolande Sérandour","doi":"10.5235/20488432.3.1.61","DOIUrl":"https://doi.org/10.5235/20488432.3.1.61","url":null,"abstract":"","PeriodicalId":114680,"journal":{"name":"World Journal of VAT/GST Law","volume":"3 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2014-05-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130339339","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
{"title":"The rules on the Certificate of Entry (Gelangensbestätigung)","authors":"R. Ismer, D. Endres","doi":"10.5235/20488432.3.1.50","DOIUrl":"https://doi.org/10.5235/20488432.3.1.50","url":null,"abstract":"","PeriodicalId":114680,"journal":{"name":"World Journal of VAT/GST Law","volume":"82 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2014-05-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"123359733","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article deals with the new OECD international VAT/GST Guidelines on place of supply of B2B Services and Intangibles. The Guidelines were approved by the OECD Committee on Fiscal Affairs in January 2014. The aim of the article is to analyse the new Guidelines from an EU law perspective and also from the perspective of how the Guidelines may contribute to reducing the risks of double taxation and unintended non-taxation.
{"title":"The OECD International VAT/GST Guidelines on Place of Supply of B2B Services and Intangibles","authors":"Lena Hiort af Ornäs Leijon, E. Kristoffersson","doi":"10.5235/20488432.3.1.32","DOIUrl":"https://doi.org/10.5235/20488432.3.1.32","url":null,"abstract":"This article deals with the new OECD international VAT/GST Guidelines on place of supply of B2B Services and Intangibles. The Guidelines were approved by the OECD Committee on Fiscal Affairs in January 2014. The aim of the article is to analyse the new Guidelines from an EU law perspective and also from the perspective of how the Guidelines may contribute to reducing the risks of double taxation and unintended non-taxation.","PeriodicalId":114680,"journal":{"name":"World Journal of VAT/GST Law","volume":"394 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2014-05-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"123369183","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The quintessentially eccentric style in which the Australian GST is drafted has led the High Court of Australia to suggest that Australia's GST differs from other value added taxes in respect of the basic concept of a ‘supply for consideration’. This article examines the five most significant Australian cases on this concept, which deal with cancelled transactions, subsidies, and business incentive payments. A detailed analysis of these cases reveals that the issues that arise and the arguments made in respect of those issues—though not always the conclusions reached—are hardly unusual in the context of a VAT, and it remains unclear just how different the Australian GST really is.
{"title":"Grappling with basic VAT concepts in the Australian GST: the meaning of ‘supply for consideration’","authors":"R. Millar","doi":"10.5235/20488432.3.1.1","DOIUrl":"https://doi.org/10.5235/20488432.3.1.1","url":null,"abstract":"The quintessentially eccentric style in which the Australian GST is drafted has led the High Court of Australia to suggest that Australia's GST differs from other value added taxes in respect of the basic concept of a ‘supply for consideration’. This article examines the five most significant Australian cases on this concept, which deal with cancelled transactions, subsidies, and business incentive payments. A detailed analysis of these cases reveals that the issues that arise and the arguments made in respect of those issues—though not always the conclusions reached—are hardly unusual in the context of a VAT, and it remains unclear just how different the Australian GST really is.","PeriodicalId":114680,"journal":{"name":"World Journal of VAT/GST Law","volume":"19 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2014-05-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"132691156","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
In June 2013, the French Supreme Court issued a favourable decision concerning VAT deduction on expenses incurred in the course of a share purchase transaction. This article revisits the context of this decision and explains the case. L’Air Liquide SA is an active French holding company involved in industrial gas production and also in the management of its subsidiaries. L’Air Liquide SA had planned to purchase 11 subsidiaries of the Messer Group, a competitor of Air Liquide SA. To achieve this purchase, L’Air Liquide SA hired the services of a French bank and an audit firm. After the preliminary due diligence work, however, L’Air Liquide SA decided not to purchase five of the targeted subsidiaries. L’Air Liquide SA finally concluded a sale purchase agreement with the Messer Group for the six remaining subsidiaries, which also provided a substitution clause to the benefit of one of its subsidiaries: Air Liquide International, an old sub-holding entity which mainly owned non-French subsidiaries. Ultimately, relying on this clause, it was Air Liquide International that acquired the subsidiaries from the Messer Group. The French tax administration denied the deductibility of VAT on the costs incurred for the purchase of the subsidiaries by L’Air Liquide SA. The French tax administration argued that L’Air Liquide SA was not the effective beneficiary of the transactions as it never intended to buy the shares itself. Thus, it had no economic purpose for incurring the costs involved in the deal.
{"title":"Deductibility of VAT on expenses incurred for the purchase of shares by a holding: a helpful French Supreme Court decision","authors":"Odile Courjon","doi":"10.5235/20488432.3.1.55","DOIUrl":"https://doi.org/10.5235/20488432.3.1.55","url":null,"abstract":"In June 2013, the French Supreme Court issued a favourable decision concerning VAT deduction on expenses incurred in the course of a share purchase transaction. This article revisits the context of this decision and explains the case. L’Air Liquide SA is an active French holding company involved in industrial gas production and also in the management of its subsidiaries. L’Air Liquide SA had planned to purchase 11 subsidiaries of the Messer Group, a competitor of Air Liquide SA. To achieve this purchase, L’Air Liquide SA hired the services of a French bank and an audit firm. After the preliminary due diligence work, however, L’Air Liquide SA decided not to purchase five of the targeted subsidiaries. L’Air Liquide SA finally concluded a sale purchase agreement with the Messer Group for the six remaining subsidiaries, which also provided a substitution clause to the benefit of one of its subsidiaries: Air Liquide International, an old sub-holding entity which mainly owned non-French subsidiaries. Ultimately, relying on this clause, it was Air Liquide International that acquired the subsidiaries from the Messer Group. The French tax administration denied the deductibility of VAT on the costs incurred for the purchase of the subsidiaries by L’Air Liquide SA. The French tax administration argued that L’Air Liquide SA was not the effective beneficiary of the transactions as it never intended to buy the shares itself. Thus, it had no economic purpose for incurring the costs involved in the deal.","PeriodicalId":114680,"journal":{"name":"World Journal of VAT/GST Law","volume":"42 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2014-05-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"126700861","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2013-12-30DOI: 10.5235/20488432.2.3.261
E. Kristoffersson
In Scania Metall, in a judgment of 15 March 2013, the Swedish Supreme Administrative Court ruled that the right to deduct input VAT depends on whether the taxpayer was in good or bad faith in respe ...
{"title":"Tax fraud, tax abuse and the right to deduct input VAT in Sweden","authors":"E. Kristoffersson","doi":"10.5235/20488432.2.3.261","DOIUrl":"https://doi.org/10.5235/20488432.2.3.261","url":null,"abstract":"In Scania Metall, in a judgment of 15 March 2013, the Swedish Supreme Administrative Court ruled that the right to deduct input VAT depends on whether the taxpayer was in good or bad faith in respe ...","PeriodicalId":114680,"journal":{"name":"World Journal of VAT/GST Law","volume":"16 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2013-12-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"132132433","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
京公网安备 11010802042870号
京ICP备2023020795号-1
扫码关注我们
求助内容：
应助结果提醒方式：