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InTouch Australia India
Asia Pacific VAT/GST Alert InTouch with indirect tax news Issue 02/14 • Notifications/Circulars for VAT • VAT case laws • Service Tax case laws Welcome to issue 02/14 of InTouch* which covers developments in VAT/GST in Asia Pacific during the period April 2014 to June 2014. • Implementation of VAT for exporting garments, textiles, footwear, bags, handbags and headwear • VAT on import and supply of certain agricultural products • VAT on contractors supplying rice for export New Zealand Please feel free to reach out to any of the PwC contacts on the back of this issue. China Singapore Australia • GST rulings • GST Cases update Cambodia • Telecommunications sector joins B2V pilot program • Simplified VAT levy rate structure India • Hire firm security bonds Philippines • Application for Value-Added Tax (VAT) Refund/Credit under Section 112 of the Tax Code • E-tax guide on the attribution of input tax Vietnam • New decree and circular on invoicing Australia GST Rulings GST Cases Update • GSTR 2014/D1: This ruling explains the Commissioner’s preliminary views on the GST consequences of incentive payments made by motor vehicle manufacturers, importers and distributors to motor vehicle dealers. It is intended to provide practical guidance to the motor vehicle industry following the decision of the Full Federal Court in AP Group Limited v Commissioner of Taxation [2013] FCAFC 105. MBI Properties Pty Limited v Commissioner of Taxation [2013] FCAFC 112 • GSTD 2014/D1: This ruling sets out the Commissioner’s preliminary view that the supply of a credit card facility will be GSTfree to the extent it is intended that the cardholder will use the facility to undertake a transaction when they are physically outside Australia. • GSTD 2014/D2: This ruling sets out the Commissioner’s preliminary view that payments made by a vendor to a purchaser of real property when the rent received falls below the rental yield guaranteed by the vendor, give rise to an adjustment event under Division 19 in the GST Act. The Commissioner has been granted special leave to appeal to the High Court against the decision of the Full Federal Court. The Full Federal Court decided that the taxpayer (MBI) was not required to make increasing adjustments under Division 135 in the GST legislation in relation to the acquisition of residential units as part of a GSTfree going concern. Living Choice Australia Limited v Commissioner of Taxation [2014] AATA 168 The Administrative Appeals Tribunal (AAT) affirmed the Commissioner’s objection decision regarding calculation of input tax credits in relation to the construction and operation of retirement villages which provide independent living units (ILUs) for occupation by their residents. The taxpayer’s entitlement to input tax credits turned on the extent to which the “residential premises” (as defined) supplied to the residents included communal facilities and services. Lighthouse Financial Advisers (Townsville) Pty Ltd [2014] AATA 301 The AAT found that payment made in settlement of a legal matter was not consideration for a taxable supply. For more information, please contact: Peter Konidaris [email protected] +61 3 8603 1168 Cambodia Implementation of VAT for exporting garments, textiles, footwear, bags, handbags and headwear The Ministry of Economy and Finance (“MEF”) has issued Prakas No. 311 MEF.Prk dated 19 March 2014 on the implementation of VAT for supporting industries or contractors supplying products or services for the purpose of exporting the garments, textiles, footwear, bags and handbags and headwear. The supporting industries and contractors are separately defined in the Prakas. The Prakas replaces Prakas No. 298 MEF.Prk dated 17 June 2005, which covered only the garment, textile and footwear industries. The VAT implications for supporting industries or contractors that supply products or services to the main industries for the purpose of exporting such products are as follows: Input VAT • For the supporting industries, VAT on the import of production inputs and equipment used to produce supplies for the main industries is borne by the government. If an entity intends to sell such production inputs and equipment, it must notify the Customs and Excise Department (“GDCE”) of its intention in advance. Any sale of the production input and equipment locally will be subject to VAT at 10%. • However, the same incentives do not apply to contractors. Any imports or local purchases of production inputs and equipment used to produce supplies for the main industries are subject to 10% VAT. Output VAT • For supporting industries and contractors, 0% VAT will apply to the supply of products or services to the main industries for exporting purposes and 10% VAT will be applied if the products or services are supplied to the local market. • For contractors, 10% VAT will be applied to any shortfall in the quantity/quality of the finished products (as per the sale agreement) supplied by the contractors if the contractors receive the production inputs from the main industries. In this event, the main industries are also liable for the customs duties and taxes applied on the imported production inputs. • To be entitled to the above incentives, the supporting industries and contractors are required to meet certain requirements (e.g. obtain approval from the MEF and submit the sales contracts to the General Department of Taxation) as outlined in the new Prakas. VAT on import and supply of certain agricultural products The MEF has issued Prakas No. 312 MEF.Prk dated 19 March 2014, which replaces Prakas No. 303 MEF.Prk dated 23 May 2001. The new Prakas stipulates that VAT on the import and supply of certain agricultural products shall be borne by the government. Such products include all types of fertilisers, plant seeds, animal medicines, animal foods, animal species, and agricultural machinery and tools. VAT on contractors supplying rice for export The MEF has issued Prakas No. 313 MEF. Prk dated 19 March 2014 which grants VAT incentives to contractors who supply milled rice and supporting services to the rice exporters for exporting purposes. Input VAT • VAT on the import of production inputs and equipment imported to produce milled rice for export is borne by the government. However, local purchases of production inputs, except for paddy rice, are subject to 10% VAT. China Output VAT • The direct supply of milled rice or milled rice production services to the rice exporters for exporting purposes is subject to 0% VAT. However, 10% VAT will be applied to such supplies for the local market. • If contractors import production materials for production of milled rice but do not supply such milled rice to the exporters based on the quantity and production standard, the contractors will need to pay 10% VAT on the shortfall. The contractors will also need to pay customs duty and other taxes on the production materials. • To be entitled to the above incentives, entities in supporting industries and contractors are required to fulfil certain requirements (e.g. to obtain approval from the MEF and to submit the sale contracts to the General Department of Taxation) as outlined in the new Prakas. For more information, please contact: Heng Thy [email protected] Tel: +855 23 218 086 Telecommunications sector joins B2V pilot program With effect from 1 June 2014, the telecommunications sector comes under the B2V Pilot Program. Units and individuals supplying telecommunications services within China become VAT payers and are required to comply with the Caishui Circular [2014] No. 106 for the payment of VAT. They no longer pay Business Tax. Caishui Circular [2014] No. 43 defines two categories of services. Basic telecommunications services are subject to VAT at 11% and value-added services at 6%. However, units and individuals providing telecommunication services to units outside of China are exempt from VAT. Telecommunications services that are redeemed using reward points are not subject to VAT. Taxpayers are required to separately account for the VAT on goods such as user cards and set-top boxes as well as telecommunications services that are bundled free of charge together with the telecommunications services they provide. As a transitional measure, units that transmit digital data and information and provide voice telephony via satellite and who are General VAT Payers may elect to account for VAT using the Simplified Method, prior to 31 December 2015. Simplified VAT Levy Rate Structure The Ministry of Finance and the State Administration of Taxation have jointly issued the Caishui Circular [2014] 57 (“Circular 57”) on “Tax Policy Regarding the Simplification and Combination of the VAT Levy Rates”. The Circular takes effect on 1 July 2014. In addition to the current VAT Rate structure, China has a system of VAT Levy Rates of 3%, 4% and 6% that generally applies under certain circumstances involving the use of the Simplified Method. The system is further complicated by the availability of concessionary Levy Rates at half of the applicable Levy Rate in certain situations. With effect from 1 July 2014, China will standardise the VAT Levy Rate to 3%. Among other beneficiaries, VAT General Payers who produce and supply tap water and cement for commercial use and elect to use the Simplified Method will use the 3% VAT Levy Rate instead of the current 6% VAT Levy Rate. For more information, please contact: Alan Wu [email protected] +86 10 6533 2889 India Notifications/Circulars for VAT Karnataka Delhi • The electronic filing of sales/stock transfer and purchase/receipt listing in various annexure(s) have been made mandatory for dealers having a total turnover of INR 5 Mn or more during the FY 2013-14 or in any subsequent year, along with periodical returns for the tax period starting May 2014. • With effect from 26 March 2014, the facility of affixing a digital signature on returns and other documents filed electronically was introduced. 46th amendment to the Constitution of India, “Test of dominant nature”/ “Test of degree of intention” was not applicable in the case of composite contracts involving supply of goods and provision of labour or services, which fell within the ambit of clause 29A(b) of Article 366 of the Constitution. • The electronic filing of sales and purchase listing in annexure(s) J1 and J2 has been made mandatory along with filing of periodical returns for the tax period starting April 2014. • With effect from 23 May 2014, the rate of VAT on cell phones having retail price in excess of INR 10,000 has been increased from 5.25% to 8.40%. Tamil Nadu VAT Case Laws • The Delhi High Court, in Anchor Electricals (P) Ltd v Commissioner of Sales Tax (2014-VIL81-Del), held that while classifying a product under the relevant entry description of any schedule, reference to HSN or central excise tariff should be made only when the relevant entry description referred to the HSN based classification. In other cases, the classification had to be done on the basis of the common parlance test. • With effect from 1 April 2014, the time limit for filing monthly returns has been extended from the 12th day of the subsequent month to the 20th day of the subsequent month for dealers having taxable turnover of INR 2000 Mn or more for the preceding year. • The Constitution Bench of Supreme Court in Kone Elevators India Pvt Ltd v State of Tamilnadu (Writ Petition No 232 of 2005) held that the transaction of manufacture, supply and installation of lifts was a works contract and not a contract for the sale of lifts. The Supreme Court (“SC”) has reversed the principles laid down by a three member bench of the SC in the case of Kone Elevator India Pvt Ltd (2005-3-SCC 389). The SC reiterated the position of the law that pursuant to the • The Bombay High Court in Additional Commissioner of Sales Tax v Kirloskar Copeland Ltd (2014-VIL-120-Bom) held that a contract for exchange of defective compressor with a repaired compressor was a cross transfer of property between defective compressor and repaired compressor and not a contract for sale of repaired compressor. In this case, the customer was required to pay repair charges wherein the customer has two options: a) wait for 60 days and get the defective compressor Maharashtra • With effect from 1 April 2014, the electronic payment of tax has been made mandatory for dealers having taxable turnover of more than INR 20 Mn for the preceding year. Haryana duly repaired; or b) take a repaired compressor of the same capacity, model and size. The Court has held that the repair charges paid by the customer for accepting the repaired compressor of the same capacity could not be treated as the price for the sale of the repaired compressor as there was no consensual agreement for the sale of the repaired compressor. • The Orissa High Court, in State Bank of India v State of Odisha (2014-VIL-117-Ori), held that the “bank” was a dealer liable to pay VAT on the sale of goods in an auction conducted by it to recover loan dues. • The Himachal Pradesh High Court in Bharat Sanchar Nigam Ltd v State of Himachal Pradesh (2014-VIL-93-HP) held that no sales tax could be levied on supply of SIM cards to subscribers as the SIM cards had no intrinsic value and it was supplied to the customer for providing telephone services. The Court has relied on the Supreme Court decision in the matter of Idea Mobile Communication Limited (2011-VIL-17-SC-ST). Service Tax Case Laws • A two-member bench of the Bombay High Court, in Indian Hotels and Restaurant Association and ors v UoI and ors (2014-TIOL- 498-HC-MUM-ST) upheld the constitutional validity of the levy of service tax on the supply of food and beverages by hotels, restaurants, etc. The Bombay High Court ruling was contrary to the decision of the Kerala High Court in Kerala Classified Hotels and Resorts Association v UoI (2013-TIOL-533-HC-KeralaST). of goods, recommending manufacturing process and vendors, reporting the status of manufacture, analyzing samples, inspecting export consignments and issuing inspection certificates were ‘business auxiliary services’ (BAS). These services, though provided in India, were used by the foreign entity for its business outside India. Hence the services qualify as export of services. • The Bombay High Court, in CST v SGS India Pvt Ltd (2014-TIOL-580-HC-MUM-ST) held that the technical testing and analysis services rendered by an Indian service provider to foreign importers, to certify the importworthiness of the goods to be exported by Indian exporters, though provided in India, were consumed outside India. Therefore, such services qualify as export of services. • In Religare Securities Ltd v CST and CST v Religare Securities Ltd (2014- TIOL-539CESTAT-DEL), the Delhi Tribunal held that the ‘delayed payment charges’ collected by service providers from clients who failed to make payment within the agreed time period, were penal in nature and could not be held liable to service tax. • The Gujarat High Court, in CST v Zydus Technologies Ltd (2014-TIOL-613-HC-AHMST) held that the input services used before the commencement of manufacturing or, as in the instant case, before the grant of approval to commence ‘authorised operations’ by the SEZ unit, was eligible for CENVAT credit. A refund of the same could be claimed subject to conditions. • In JP Transformers v CCEST (2014-TIOL-664CESTAT-DEL), the Delhi Tribunal held that in a repair and maintenance contract where the value of goods/material and the value of labour/services had been separately disclosed and the applicable excise duty/VAT charged on the value of goods, service tax would be payable only on the value of labour/service charges. • In Gap International Sourcing (India) Pvt Ltd v CST (2014-TIOL-465- CESTAT-DEL), the Delhi Tribunal held that services rendered to a foreign entity relating to the procurement • In PSL Ltd v CCE (2014-TIOL-675-CESTATAHM), the Ahmedabad Tribunal held that where, on the basis of an audit objection, tax was paid under reverse charge on foreign agency commission charges, which was later found to be not payable, refund of the same could be claimed subject to unjust enrichment test. • In Khem Sales Agencies v CCE (2014-TIOL708-CESTAT-DEL), the Delhi Tribunal held that in a works contract where the value of taxable services had been separately mentioned in the agreement as well as on the invoices, the same could not be treated as an indivisible works contract. Accordingly, service tax would be payable only on the value of the contract which pertained to taxable services. • In Gujarat Nippon Enterprise Pvt Ltd v CST (2014-TIOL-784-CESTAT-MUM), the Mumbai Tribunal held that where advance money was returned on cancellation of the service agreement, the amount of service tax paid at the time of receipt of advance money could be claimed as refund as the tax was paid inadvertently. • The Delhi Tribunal, in Agarwal Motors v CCE (2014-TIOL-827-CESTAT-DEL) held that where commission received had been reversed for non-provision or non-completion of services, service tax paid by the commission agent at the time of receipt of commission could be reversed/adjusted against future liability. • In B4U Television Network (I) P Ltd v CST (2014-TIOL-884-CESTAT-MUM), the Mumbai Tribunal held that excess service tax paid during the period 2001 to 2002 could be selfadjusted against service tax liability for the period October 2002 to March 2003 under rule 6(3) of Service Tax Rules, 1994, and that there was no need to file a refund claim instead. • In Hyundai Motor India Engineering Pvt Ltd v CCECST (2014-TIOL-1034-CESTAT-BANG), the Bangalore Tribunal held that for the purpose of calculation of limitation period for filing refund claim towards the export of services, the relevant date was the date of receipt of payment for services exported, not the date when the services were provided. For more information, please contact: Vivek Mishra [email protected] +91 124 330 6518 Anita Rastogi [email protected] +91 124 330 6531 New Zealand Hire firm security bonds The Inland Revenue has recently published their current view on the GST treatment of security bonds paid to hire firms. The central example discussed by Inland Revenue is the payment of a bond by a customer to a hire (or leasing) firm. For GST to apply to a transaction, a registered person must make a supply for consideration in the course of or furtherance of a taxable activity. The Commissioner’s view is that the initial payment of a bond is not for any supply, and thus is not subject to GST. The initial payment of a bond arises in the context of a supply of hired goods, but the payment is not for that supply. For more information, please contact: Eugen Trombitas [email protected] +64 9 355 8686 The conclusion is that no GST applies to the bond. The draft item helpfully discusses a number of other scenarios/payments (or uses of the bond) and whether GST applies. This development is useful because it draws out a distinction between fees that are subject to GST and those that are not and affirms that not all business receipts are subject to GST. The same rules apply if all or part of a bond is sacrificed as compensation to the hirer for damage to, or loss of, the goods or for breaching a condition of hire. The forfeited bond is not consideration for a supply; instead it is a payment for damages. The Commissioner’s view is that GST will not apply where the payment is compensation for damages. Ian Rowe [email protected] The Commissioner’s previous view was that GST was payable in respect of bonds paid as security on hire goods if the bond was sacrificed as a result of a contingency such as non-compliance with the bond conditions. The amount of the bond appropriated was seen as consideration for a taxable supply and subject to GST. However, GST is payable when all or part of the bond is forfeited as payment of an extra hire charge, such as a late return fee. If the hire firm and the customer agree that all or a portion of the bond will be used to purchase the hired goods, then GST will apply to that sale in the ordinary way. When a customer hires goods, they are often required to pay a bond as a form of collateral in the event that the hire goods are damaged, not returned, or the customer breaches a term of the hire agreement. We expect that business-to-business transactions will be GST neutral, but it would still be beneficial to check the GST treatment adopted. For business-to-customer transactions (where customers are not GST-registered), there may be an opportunity to improve your margin by checking the GST treatment. Gary O’Neill [email protected] +64 9 355 8432 Philippines Application for Value-Added Tax (VAT) Refund/Credit under Section 112 of the Tax Code The Commissioner of Internal Revenue (“CIR”) has issued a Revenue Memorandum Circular (“RMC”) No. 54-2014 dated 11 June 2014 to summarize the rules on filing and processing of applications for VAT refund/tax credit based on cases decided by the Supreme Court. The salient points of the RMC are as follows: 1. Prescriptive period within which administrative claim for refund or tax credit of input tax should be made Tax refunds relating to zero-rated or effectively zero-rated sales must be filed within 2 years after the close of the taxable quarter when sales were made in accordance with Sec. 112 (A) of the Tax Code. The CIR shall have 120 days from date of submission of complete documents to decide whether or not to grant the claim for refund or issue a Tax Credit Certificate (TCC) for creditable input taxes. If no action is made by the CIR within the 120-day period, such “inaction shall be deemed a denial” of the application for tax refund or TCC. 2. Filing and Processing of Administrative Claims Applications for VAT refund/TCC must be accompanied by complete supporting documents as enumerated under the “Checklist of Mandatory Requirements for Claims for VAT Credit/Refund”. The taxpayer shall attach a statement under oath attesting to the completeness of submitted documents. In case of juridical (corporate) applicants, that statement should be accompanied by a sworn certification signifying that the signing officer (i.e. at the very least, the Chief Financial Officer) is authorised by the Board of Directors. The checklist and sworn certification (Annexes “A” and “B” of the RMC) can be downloaded from http://www.bir.gov.ph/. Upon submission of the administrative claim and its supporting documents, the same shall be processed and no other documents shall be accepted/requested from the taxpayer. 3. Mandatory 120+30 Day Period In case of full or partial denial of the claim for tax refund or TCC, or the failure on the part of the CIR to act on the application within the period prescribed above, the taxpayer affected may file an appeal in one of two ways: (1) file the judicial claim within 30 days after the Commissioner denies the claim within the 120day period, or (2) file the judicial claim within 30 days from the expiration of the 120-day period if the Commissioner does not act within such period. 4. Exception to the Mandatory and Jurisdictional Nature of the 120+30 day Period As an exception to the 120+30 day period, it was emphasised that from the time of issuance of BIR Ruling No. DA-489-03 on December 10, 2003 up to its reversal by the Supreme Court in the Aichi case on 6 October 2010 (or a period of almost 7 years), taxpayers/claimant need not wait for the lapse of the 120-day period before it could seek judicial relief with the Court of Tax Appeals (CTA). This exception, however, is limited to cases of premature filing (filing of judicial claim prior to the lapse of the 120-day period) and does not extend to late filing of a judicial claim. Singapore 5. Pending Administrative Claim The CIR shall lose jurisdiction over an administrative claim once the taxpayer has filed a “petition for review” with the CTA. Failure to file the judicial claim with the CTA within 30 days from expiration of the 120day period shall render the Commissioner’s decision or inaction which is “deemed a denial”, final and unappealable. This rule will apply to all pending administrative claim for refund/tax credit. The Circular shall take effect immediately. For more information, please contact: Malou P. Lim, Partner [email protected] +63 2 459 2016 E-tax guide on the attribution of input tax The Inland Revenue Authority of Singapore (“IRAS”) has issued a guide to explain how a partially exempt business is to attribute its input tax and when input tax may be considered to be “directly attributable” to a supply. In summary, • The IRAS has indicated that it would treat the the input tax incurred on a purchase of a good or service to be “directly attributable” to a supply if – the purchase forms a cost component of a supply; or – the purchase is being used as an input or will be used to make the supply. • Input tax incurred on the purchase of a good or service is directly attributable to a taxable supply only if there is no intervening exempt supply. For more information, please contact: Koh Soo How [email protected] +65 6236 3600 Weijie Lin [email protected] +65 6236 7481 Vietnam New decree and circular on invoicing The Government has recently issued Decree 04/2014/ND-CP partly amending Decree 51/2010/ND-CP on invoicing. Decree 04 took effect from 1 March 2014. Following the Decree, the Ministry of Finance has issued Circular 39/2014 on invoicing regulations providing guidance on the implementation of Decree 51/2010/ ND-CP and Decree 04/2014/ ND-CP. Circular 39 replacing Circular 64/2013 became effective on 1 June 2014. The notable changes include: • Export invoices are abolished. Instead, VAT invoices are used for the export of goods or the provision of services to foreign countries or non-tariff areas. For Export Processing Enterprises, sales invoices are used for both domestic and export sales. • Individuals and households who are required to issue invoices must purchase pre-printed invoices from the tax authorities. • Subject to various other conditions, companies are permitted to use self-printed invoices if (i) their charter capital is at least VND 15 billion (USD 715k) or (ii) their charter capital is below VND 15 billion but their total historical cost of fixed asset is at least VND 1 billion (USD 48k). • Use of self-printed/pre-printed invoices now requires approval from the tax authorities (previously only a notification was required). • The name and tax code of the self-printedinvoice software provider is no longer required to be disclosed on the self-printed invoice. • The following enterprises are now required to purchase invoices from the tax authorities: – Enterprises declaring VAT on a deemed basis (i.e. not the conventional credit system); – “High tax risk” enterprises; – Enterprises using self-printed invoices/preprinted invoices which have been penalised for tax evasion. • “High tax risk” enterprises include inter alia enterprises which its owners’ equity is less than VND 15 billion and submit their tax declarations more than 90 days after the deadline, or enterprises with more than 50% of their revenue coming from companies owned by family members. • Companies considered as “high tax risk” are required to use software downloaded from the website of the General Department of Taxation to print self-printed invoices if they do not want to purchase invoices from the tax authorities. • The requirement to cross the blank section of the VAT invoice is not applied for self-printed invoices/pre-printed invoices printed by computer. For more information, please contact: Richard J Irwin (84) (8) 3 823 0796 [email protected] Contacts Australia Peter Konidaris, Partner [email protected] Tel: +61 3 8603 1168 Japan Masanori Kato, Partner [email protected] Tel: +81 3 5251 2536 Philippines Malou P. Lim, Partner [email protected] Tel: +63 2 459 2016 Vietnam Richard J. Irwin, Partner [email protected] Tel: +84 8 3823 0796 Cambodia Heng Thy, Partner [email protected] Tel: +855 23 218 086 Kotaku Kimu, Director [email protected] Tel: +81 3 5251 2713 Singapore Koh Soo How, Partner [email protected] Tel: +65 6236 3600 David Fitzgerald, Partner [email protected] Tel: +84 8 3824 0116 China Alan Wu, Partner [email protected] Tel: +86 10 6533 2889 India Vivek Mishra, Executive Director [email protected] Tel: +91 124 330 6518 Anita Rastogi, Associate Director [email protected] Tel: +91 124 330 6531 Laos Thavorn Rujivanarom, Partner [email protected] Tel: +662 344 1444 Malaysia Wan Heng Choon, Senior Executive Director [email protected] Tel: +60 3 2173 1488 New Zealand Eugen Trombitas, Partner [email protected] Tel: +64 9 355 8686 Indonesia Ali Widodo, Partner [email protected] Tel: +62 21 52890623 Gary O’Neill, Director [email protected] Tel: +64 9 355 8432 Abdullah Azis, Associate Director [email protected] Tel: +62 21 5289 0601 Ian Rowe, Director [email protected] Tel: +64 4 462 7274 Weijie Lin, Manager [email protected] Tel: +65 6236 7481 South Korea Dong-Keon (D.K.) Lee, Partner [email protected] Tel: +82 2 709 0561 Sri Lanka Hiranthi Ratnayake, Director [email protected] Tel: +94 11 4719838 Taiwan Lily Hsu, Partner [email protected] Tel: +886 2 2729 6666 Ext. 26207 Thailand Somboon Weerawutiwong, Partner [email protected] Tel: +662 344 1000 Ext. 1247 For a comprehensive guide to global VAT/GST information from over 70 countries worldwide, please visit GlobalVATOnline at www. globalvatonline.com. GlobalVATOnline can keep you up to date on all VAT issues and developments as they unfold. Disclaimer. Clients receiving this Alert should take no action without first contacting their usual PwC Indirect Tax Advisor. © 2014 PricewaterhouseCoopers. All rights reserved. Not for further distribution without the permission of PwC. “PwC” refers to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL), or, as the context requires, individual member firms of the PwC network. 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