Skip to main content Accessibility help
×
Hostname: page-component-78c5997874-s2hrs Total loading time: 0 Render date: 2024-11-09T13:56:34.369Z Has data issue: false hasContentIssue false

3 - Varieties of VAT in Use

Published online by Cambridge University Press:  05 February 2015

Alan Schenk
Affiliation:
Wayne State University School of Law
Victor Thuronyi
Affiliation:
Duke University School of Law
Wei Cui
Affiliation:
University of British Columbia, Vancouver
Get access

Summary

Introduction

Several leading forms of VATs in OECD countries can be identified. This chapter describes the main VAT variants. The most influential is the harmonized VAT in the European Union (EU) member states. The EU model has the most extensive case law on VAT issues.

New Zealand departed from the EU model in a number of significant ways, including the expansion of the tax base for its Goods and Services Tax (GST) by limiting exemptions and zero-rating and by taxing many government services. South Africa modeled its VAT after the New Zealand GST but included some of its own unique features. For example, South Africa taxes all fee-based financial services. Australia’s GST is also inspired by the New Zealand model, but there are significant departures.

Japan departed from the EU model by requiring registered firms to calculate periodic tax liability in a different fashion. Under the Japanese Consumption Tax (CT), taxable i rms are not required to issue VAT invoices, which represent a central feature of other VAT regimes.

Canada has a national VAT (known as GST) and several provinces have harmonized VATs. The combined Quebec-national GSTs are administered by Quebec. The combined national and provincial HSTs (the Harmonized Sales Tax) are administered at the national level.

Type
Chapter
Information
Value Added Tax
A Comparative Approach
, pp. 47 - 58
Publisher: Cambridge University Press
Print publication year: 2015

Access options

Get access to the full version of this content by using one of the access options below. (Log in options will check for institutional or personal access. Content may require purchase if you do not have access.)

References

Kronbergs, Z., “Survey of Latvia’s VAT Legislation,” 6 Int’l VAT Monitor350 (Nov./Dec. 1995)Google Scholar
Mastrapasqua, P., “Current Status in Italy of EC Directives Regarding Taxation,” 26 Intertax413 (1998)Google Scholar
Schenk, A., “Japanese Consumption Tax: The Japanese Brand VAT,” 42 Tax Notes1625 (Mar. 27, 1989)Google Scholar
Schenk, , “Japanese Consumption Tax after Six Years: A Unique VAT Matures,” 69 Tax Notes899, 911 (Nov. 13, 1995)Google Scholar
Pyanic, P. and Fife, A., “GST Treatment of Appropriations – Where Are We Now and Is the Nature of the Payment Relevant?,” 9 Australian GST Journal105 (Oct. 2009)Google Scholar
Millar, R., “Cross-border Services,” in VAT in Africa (Krever, R., ed., Pretoria University Law Press, 2008)

Save book to Kindle

To save this book to your Kindle, first ensure [email protected] is added to your Approved Personal Document E-mail List under your Personal Document Settings on the Manage Your Content and Devices page of your Amazon account. Then enter the ‘name’ part of your Kindle email address below. Find out more about saving to your Kindle.

Note you can select to save to either the @free.kindle.com or @kindle.com variations. ‘@free.kindle.com’ emails are free but can only be saved to your device when it is connected to wi-fi. ‘@kindle.com’ emails can be delivered even when you are not connected to wi-fi, but note that service fees apply.

Find out more about the Kindle Personal Document Service.

Available formats
×

Save book to Dropbox

To save content items to your account, please confirm that you agree to abide by our usage policies. If this is the first time you use this feature, you will be asked to authorise Cambridge Core to connect with your account. Find out more about saving content to Dropbox.

Available formats
×

Save book to Google Drive

To save content items to your account, please confirm that you agree to abide by our usage policies. If this is the first time you use this feature, you will be asked to authorise Cambridge Core to connect with your account. Find out more about saving content to Google Drive.

Available formats
×