Bahrain: Phased roll out of VAT in Bahrain

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The National Bureau of Taxation, operating under the Ministry of Finance, conducted their first VAT briefing session on 3rd December 2018 which was attended by several accounting firms. MOF presented the way forward on VAT implementation and addressed several concerns raised during the meeting. In light of this discussion, Grant Thornton Bahrain's VAT team has set out the key takeaways in the attached Alert.

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Not that it is expecting a ‘no-deal’ scenario – the UK Government has specifically emphasised that it fully expects the opposite - but, just in case, it has announced a number of measures relating to UK VAT should agreement between the EU and the UK not materialise. The Government considers that it is progressing well in its negotiations with the EU on the terms of Britain’s exit. However, rightly, it recognises that it is always possible that agreement will not be reached. As a consequence, it has made announcements in relation to VAT in the event of a so-called Brexit ‘no-deal’. UK businesses – especially those that trade with businesses in other Member States of the EU have had concerns on a number of fronts, not least how the UK VAT system will work after Brexit and what changes will be needed in relation to import and export procedures. The announcements made by the Government should help businesses to prepare for a ‘no-deal’ Brexit with a little more certainty. In line with the Government, businesses should not assume that an agreement will be reached. Businesses should be prepared for a ‘no-deal’ scenario even though that may not come to fruition.

UK: VAT alert - Government publicises VAT changes if there is “no-deal” on B...

UK: VAT alert - Government publicises VAT changes if there is “no-deal” on B...

UK: VAT alert - Government publicises VAT changes if there is “no-deal” on B...

The Court of Appeal has released its judgment in Adecco UK Ltd & Ors (Adecco). In dismissing Adecco’s appeal the Court confirmed the decisions of the First Tier Tribunal (FTT) and Upper Tribunal (UT) that Adecco’s supplies of temporary staff under its ‘non-employment’ contract arrangements were liable to VAT on the full value of the supply by Adecco to the client. Adecco contended that it was liable to VAT only to the extent of its administrative and ancillary charges to the client. In its view, any charges relating directly to the costs of paying temps were not liable to VAT. Adecco’s supplies of the services of ‘employed’ temps and ‘selfemployed’ temps were not in question. The dispute centred around ‘non-employed’ temps. In the case of ‘non-employed’ temps, the Court determined that the extent of control exerted by Adecco, the fact that Adecco met the temp’s PAYE/NIC and similar obligations was significant. Further, the Court found that there were no material differences in contracts with clients whether Adecco were placing employed or non-employed temps, such that the client would be unaware of any distinction. Adecco supplied the services of temps to clients. Adecco’s appeal dismissed.

Case alert - Adecco UK Ltd & Ors

Case alert - Adecco UK Ltd & Ors

Case alert - Adecco UK Ltd & Ors

The First Tier Tribunal (FTT) has released its decision in the case of The Rank Group plc (Rank). Rank operated 3 types of automated gambling machine: Fixed Odds Betting Terminals (FOBT), section 16/21 and section 31/34 machines. The issue for the FTT to consider was whether the machines were ‘similar’. If so, treating them differently for VAT purposes would offend the principle of neutrality. The CJEU had previously held that the machines in question fell within the same category (broadly referred to as slot machines). However, it was for the UK court to decide whether the machines in question were ‘similar’. If so, treating the income from such machines differently for VAT purposes would be considered to offend the principle of fiscal neutrality. The FTT determined that the correct test was to examine the betting experience from the perspective of the user. Would the user’s needs be equally met whichever machine was selected? In examining the evidence, the FTT concluded that the user experience was substantially similar and that users would select machines for a variety of reasons, often playing machines interchangeably. On the basis that such factors as machine location, atmosphere, opening hours and availability were specifically stated by the CJEU to be disregarded in this context, the FTT concluded that the machines were similar. Accordingly, the principle of fiscal neutrality was offended. Rank’s appeal allowed.

Case alert - The Rank Group plc

Case alert - The Rank Group plc

Case alert - The Rank Group plc

The Court of Appeal has issued a unanimous judgment in the appeal by Zipvit Ltd (Zipvit) against the judgment of the Upper Tribunal. Zipvit, like many other businesses, contracted with Royal Mail to supply delivery services. At the relevant time, these services were treated by Royal Mail, Zipvit and HMRC as being exempt from VAT under the UK’s implementation of the ‘postal services’ exemption. However, following the Court of Justice judgment in the ‘TNT’ case in 2009 (which ruled that VAT exemption only applied to universal postal services), it became clear to all parties (including HMRC) that the mailmedia service provided by Royal Mail should have been liable to VAT at the standard rate. On that basis, Zipvit submitted a claim for a refund of the input VAT purportedly included in the price it had paid to Royal Mail. HMRC rejected that claim and Zipvit appealed to the First-tier Tax Tribunal (FTT). The FTT dismissed the appeal as did the Upper Tribunal. Now, the Court of Appeal has dismissed Zipvit’s appeal. The judgment issued on 30 June 2018 dismisses the appeal on the basis that Zipvit had no valid VAT invoice to support its claim. A fact regarded as a fatal flaw.

Case alert - Zipvit Ltd

Case alert - Zipvit Ltd

Case alert - Zipvit Ltd

This case - a referral to the Court of Justice by the French court - delivers the judgment of the European Court with regard to the recovery of input VAT on expenditure incurred by Marle Participations SARL (‘Marle’). The company sought to recover input VAT on expenditure incurred on expenses relating to a corporate restructure. The tax authorities denied input VAT recovery on the grounds that the expenditure related to activities that were capital in nature and so fell outside the scope of VAT (thereby precluding VAT recovery). Marle argued that the letting of property by the holding company to a subsidiary amounted to ‘involvement in the management’ of the subsidiary. This involvement constituted an ‘economic activity’ so enabling VAT to be recovered on the restructuring costs. The Court has ruled that the letting of property to its subsidiary amounted to ‘involvement in the management’ of that subsidiary. As such it constituted an ‘economic activity’ carrying the right, in principle, to input VAT recovery. Such input VAT recovery was to be regarded as general expenditure of Marle (and therefore subject to the normal rules governing VAT recovery). Providing the letting services were supplied by Marle on a continuing basis, for consideration, the services were taxable and Marl could demonstrate a direct link between those services to its subsidiary and the consideration it received, input VAT could be deducted in full.

Case alert - Marle Participations SARL

Case alert - Marle Participations SARL

Case alert - Marle Participations SARL

High level slides from Grant Thornton's VAT Club seminar in London held in June 2018. Topics covered include: ECJ decision - C-580/16 Hans Bühler - Triangulation Netherlands - VAT rate change Russia - VAT rate change Bahamas - VAT rate change Angola - New VAT system Liberia - New VAT system Costa Rica - New VAT system Costa Rica - e-invoicing requirements Hungary - Electronic Invoicing Italy - Mandatory e-invoicing Australia - GST on hotel accommodation Poland - VAT split payments Spain - First penalties in relation to SII Greece - SAF-T & E-Invoicing? Argentina - VAT on digital services Columbia VAT on digital services Canada - Quebec: New QST obligations for non-resident suppliers of digital services USA: Wayfair – the Decision India - “Happy Birthday GST" - what's next New Zealand - Low value consignment relief Malaysia - GST to 0% and transition to SST United Arab Emirates - Exchange Rates for VAT purposes Kuwait - VAT postponed until 2021? GCC - Bahrain, Oman, Qatar VAT implementation latest

International Indirect Tax - Global VAT/GST update (June 2018)

International Indirect Tax - Global VAT/GST update (June 2018)

International Indirect Tax - Global VAT/GST update (June 2018)

Spain - First penalties relating to SII

Spain - First penalties relating to SII

Spain - First penalties relating to SII

On May 3, 2018, Georgia Governor Nathan Deal signed H.B. 61 enacting significant changes to sales and use tax laws, including imposing a bright-line nexus rule on certain sellers of tangible personal property. Effective January 1, 2019, any seller that conducts 200 or more separate retail sales of tangible personal property for Georgia delivery or obtains more than $250,000 in gross revenue from such sales is considered a dealer that must either register to collect and remit sales tax or notify customers of use tax obligations and report to the state that such requirements have been fulfilled.

USA: Georgia Enacts Legislation Imposing Bright-Line Nexus Collection or Repo...

USA: Georgia Enacts Legislation Imposing Bright-Line Nexus Collection or Repo...

USA: Georgia Enacts Legislation Imposing Bright-Line Nexus Collection or Repo...

On April 17, 2018, the U.S. Supreme Court considered oral arguments in South Dakota v. Wayfair, a case that may have groundbreaking implications with respect to sales and use tax nexus standards. Last year, the South Dakota Supreme Court unanimously affirmed a circuit court’s decision that a law requiring certain remote sellers that do not have a physical presence in South Dakota to collect sales tax on sales made in the state is unconstitutional. In affirming the circuit court, the South Dakota Supreme Court agreed that the law violates the physical presence requirement for sales and use taxes under Quill v. North Dakota and its application of the Commerce Clause. The U.S. Supreme Court decided to consider the case and recently heard oral arguments. Mark Arrigo, Matthew Melinson, Jamie Yesnowitz and Jeremy Jester from Grant Thornton LLP attended the hearing and provide their observations in this Alert.

U.S. Supreme Court Holds Hearing in South Dakota v. Wayfair

U.S. Supreme Court Holds Hearing in South Dakota v. Wayfair

U.S. Supreme Court Holds Hearing in South Dakota v. Wayfair

As a supplement to Grant Thornton China's China Tax Alert, China Tax Bulletin aims to provide you with a prompt and high level overview on the latest tax rules released by various authorities, especially those by China SAT and local tax authorities. Implications for your business are also presented for the tax rules. The latest issue of China Tax Bulletin covers the following topics: * New Rules Issued on Deferral of Withholding Tax on Dividends Paid to Foreign Investors and Reinvested in China * SAT Releases 2017 Enterprise Income Tax Return Forms Clarifications on the filing of tax exemption for cross-border taxable activities and other VAT-related issues * Government Issues More Guidance Clarifying Issues Arising from VAT Reform  State Administration of Taxation Further Clear the Determination of “Beneficial Owner” We hope you can like our sharing and find it beneficial to your daily business. At the same time, please feel free to contact us for any further clarification on any of the covered tax issues.

China tax bulletin - Issue 2 April 2018

China tax bulletin - Issue 2 April 2018

China tax bulletin - Issue 2 April 2018

These are the slides from the International Indirect Tax - Global VAT/GST update presented at Grant Thornton's VAT Club held in London on 9th March 2018. The topics discussed include: EU • Bulgarian Presidency • VAT Action Plan – proposal for a Definitive VAT System based on destination principle • Customs: Binding Valuation Information (BVI) • Considerations for using TP for Customs value • Hungary: Electronic Invoicing • Spain: SII 1.1 new version • Italy: Simplifications to “Communications of data of invoices issued and received” • Italy: Mandatory e-invoicing? EMEA • South Africa: VAT rate increase • GCC – where are we? • UAE: What's been released ? What's missing? Designated Zones NOAM • USA: Landmark sales tax nexus case to be heard in Supreme Court APAC • India: GST update • China: Further VAT reform • Malaysia: GST Compliance Assurance Program (MyGCAP) • Singapore: Future GST rate increase / reverse charge • Australia: Final guidance published for online retailers - GST on low value imported goods This publication has been prepared only as a high level guide. No responsibility can be accepted by us for loss occasioned to any person acting or refraining from acting as a result of any material in this publication.

International Indirect Tax - Global VAT/GST update (March 2018)

International Indirect Tax - Global VAT/GST update (March 2018)

International Indirect Tax - Global VAT/GST update (March 2018)

Subsequent to Grant Thornton China's last update in July 2017, this VAT Alert summarizes some of the further significant changes on VAT regulations for your reference. - Revision of the “Provisional Regulations of the People's Republic of China on Value-added Tax” (Referred to as “VAT regulation revision 2017“) - Clarification on Input VAT Issues - VAT regulations on specified financial products - Changes on VAT invoices - Simplified tax administration on registration of general VAT payers

China: Tax Bulletin－Latest update on VAT Regulations

China: Tax Bulletin－Latest update on VAT Regulations

China: Tax Bulletin－Latest update on VAT Regulations

India: Recommendations from GST Council in 25th meeting

India: Recommendations from GST Council in 25th meeting

India: Recommendations from GST Council in 25th meeting

On 14 December 2017, the Serbian Parliament adopted amendments to the VAT Law, which were published in the Official Gazette of the Republic of Serbia No.113/2017. The adopted amendments will go into force on January 1 2018, with exception of certain provisions for which it is particularly emphasized. On 14 December 2017, the Serbian Parliament adopted amendments to the Corporate Income Tax Law, which were published in the Official Gazette of the Republic of Serbia No.113/2017. The adopted amendments will go into force on January 1 2018, with exception of provisions regulating withholding taxation. The majority of provisions shall be applied starting from the filing of tax return for 2018. Please see a high level overview of these changes in the Tax Alert from Grant Thornton Serbia.

Serbia: Tax Alert - Amendments of Serbian Tax Laws (Dec 2017)

Serbia: Tax Alert - Amendments of Serbian Tax Laws (Dec 2017)

Serbia: Tax Alert - Amendments of Serbian Tax Laws (Dec 2017)

The New York Supreme Court, Appellate Division has held that the competitive price reports purchased by a supermarket retailer were considered to be information services that qualified for a statutory exclusion from sales tax. The Court concluded that the information services were excluded from sales tax because the information was personal or individual in nature and was not substantially incorporated into reports of others.

USA: NY - New York Appellate Division Holds Certain Data Information Services...

USA: NY - New York Appellate Division Holds Certain Data Information Services...

USA: NY - New York Appellate Division Holds Certain Data Information Services...

The UK government is going ahead with its Making Tax Digital (“MTD”) programme, starting with VAT-registered taxpayers. From 1 April 2019, businesses with a turnover above the VAT registration threshold will be required to keep specified minimum records in the VAT account and to submit the current nine- box VAT return to HMRC via Application Program Interface (“API”) software (linking either the accounting system or excel spreadsheets to the HMRC system).

UK: Briefing Paper - Are you ready for Making Tax Digital?

UK: Briefing Paper - Are you ready for Making Tax Digital?

UK: Briefing Paper - Are you ready for Making Tax Digital?

As a supplement to Grant Thornton China's China Tax Alert, China Tax Bulletin aims to provide you with a prompt and high level overview on the latest tax rules released by various authorities, especially those by China SAT and local tax authorities. Implications for your business are also presented for the tax rules. The latest issue of China Tax Bulletin covers the following topics: Preferential tax deduction regarding R&D expenses extended to small and medium sized technology enterprises; New value-added tax rules applicable to assets management products; Clarifications on the filing of tax exemption for cross-border taxable activities and other VAT-related issues; Key updates relating to the issuance of VAT invoices; Widened scope of income tax incentives for small low profit enterprises; New issued catalogue of industries for guiding foreign investment; New administration guidance on China withholding tax; and Detailed guidance on scope of concentration of super pre-tax deduction for R&D costs.

China: Tax bulletin 2017 Issue 4 - VAT

China: Tax bulletin 2017 Issue 4 - VAT

China: Tax bulletin 2017 Issue 4 - VAT

Following much anticipation and speculation the Cyprus Parliament has enacted far reaching amendments to the Cyprus VAT Law on 3/11/2017 which impact transactions related to immovable property. The amending legislation (N157(1) of 2017) was published in the Official Gazette of the Republic of Cyprus on 13/11/2017. • A significant part of the aforementioned changes involve the imposition of VAT on the supply of land. These amendments to the Cyprus VAT Law were a condition of Cyprus’ accession to the EU in 1/5/2004 for which a derogation was secured until 31/12/2007. Their enactment brings Cyprus in line with the obligations undertaken within this scope.

Cyprus: VAT Alert - VAT on building land, leasing of commercial immovable pro...

Cyprus: VAT Alert - VAT on building land, leasing of commercial immovable pro...

Cyprus: VAT Alert - VAT on building land, leasing of commercial immovable pro...

Saudi Arabia - VAT Frequently Asked Questions

Saudi Arabia - VAT Frequently Asked Questions

Saudi Arabia - VAT Frequently Asked Questions

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Germany VAT Alert: Call-Off stock - Changes in VAT treatment in Germany

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Case alert - Adecco UK Ltd & Ors

Case alert - Adecco UK Ltd & Ors

Case alert - Adecco UK Ltd & Ors

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Case alert - The Rank Group plc

Case alert - The Rank Group plc

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Case alert - Zipvit Ltd

Case alert - Zipvit Ltd

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Case alert - Marle Participations SARL

Case alert - Marle Participations SARL

International Indirect Tax - Global VAT/GST update (June 2018)

International Indirect Tax - Global VAT/GST update (June 2018)

International Indirect Tax - Global VAT/GST update (June 2018)

Spain - First penalties relating to SII

Spain - First penalties relating to SII

Spain - First penalties relating to SII

USA: Georgia Enacts Legislation Imposing Bright-Line Nexus Collection or Repo...

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USA: Georgia Enacts Legislation Imposing Bright-Line Nexus Collection or Repo...

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U.S. Supreme Court Holds Hearing in South Dakota v. Wayfair

U.S. Supreme Court Holds Hearing in South Dakota v. Wayfair

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China tax bulletin - Issue 2 April 2018

China tax bulletin - Issue 2 April 2018

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International Indirect Tax - Global VAT/GST update (March 2018)

International Indirect Tax - Global VAT/GST update (March 2018)

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China: Tax Bulletin－Latest update on VAT Regulations

China: Tax Bulletin－Latest update on VAT Regulations

India: Recommendations from GST Council in 25th meeting

India: Recommendations from GST Council in 25th meeting

India: Recommendations from GST Council in 25th meeting

Serbia: Tax Alert - Amendments of Serbian Tax Laws (Dec 2017)

Serbia: Tax Alert - Amendments of Serbian Tax Laws (Dec 2017)

Serbia: Tax Alert - Amendments of Serbian Tax Laws (Dec 2017)

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USA: NY - New York Appellate Division Holds Certain Data Information Services...

USA: NY - New York Appellate Division Holds Certain Data Information Services...

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UK: Briefing Paper - Are you ready for Making Tax Digital?

UK: Briefing Paper - Are you ready for Making Tax Digital?

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China: Tax bulletin 2017 Issue 4 - VAT

China: Tax bulletin 2017 Issue 4 - VAT

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Cyprus: VAT Alert - VAT on building land, leasing of commercial immovable pro...

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Saudi Arabia - VAT Frequently Asked Questions

Saudi Arabia - VAT Frequently Asked Questions

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Germany VAT Alert: Call-Off stock - Changes in VAT treatment in Germany

Germany VAT Alert: Call-Off stock - Changes in VAT treatment in Germany

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