VAT in the GCC - Flanders Investment and Trade

63
VAT in the GCC Brussels, 8 June 2017

Transcript of VAT in the GCC - Flanders Investment and Trade

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VAT in the GCCBrussels, 8 June 2017

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Johnson Controls ME – VAT Workshop© 2017 Deloitte & Touche (M.E.). All rights reserved. 2

VAT in the GCC

Chapter Content

Customs in the GCC • How Customs ties into VAT

• How the GCC differs from the EU customs union

Overview of VAT in the GCC

• VAT updates and timing hypothesis

• VAT fundamentals

• GCC VAT vs. the EU VAT directive

Deloitte approach toimplementation

• Our 5 phases approach

IT Systems implementation

• Lesson learnt from other implementations

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Customs in the GCC

How it ties into VAT and differences with the EU customs union

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Introduction to customs duty in the GCC

Customs Union

Formation & Common Customs Law – formed in 1981 and Common Customs Law implemented in 2002

Common framework and economic integration – coordination, interconnection and strengthening relations among member nations in all fields

Customs related memberships – WTO & WCO membership, OECD

Customs union – fully integrated single market for ease of movement of goods and services between members based on GCC Common Customs law

Background of GCC Customs Union

Oman

KSA

Qatar

Kuwait

UAE

Bahrain

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Introduction to customs duty in the GCC

Customs Union

Common rates - 0%, 5%, except KSA

Single point of entry – no internal (non-)tariff trade barriers

GCC originating products – free movement within GCC

Common exemptions/prohibitions, although some specific countries may differ in some areas/products (e.g. KSA)

Common FTAs – GCC, GAFTA, EFTA, Singapore although individual Member State FTAs also apply

Practical inconsistencies – the application of the law may differ between GCC States

Key features of GCC Customs

Union

Common Customs Law of the GCC States

Rules of Implementation to the Common Customs Law of the GCC States

Explanatory Notes to the Common Customs Law of the GCC States

National / local policies and notices

International treaties

Basic legislation framework

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Customs Exemptions

GCC Common Customs Law

• Industrial Exemptions (raw materials for manufacturing, machinery, etc.)

− Subject to certain conditions i.e. availability of the specific raw material in the local market, quantity, quality etc..

− The exemption shall be granted subject to approval from the relevant authority/ministry, in addition to other approvals which may be required

• Personal effects and household items

• Imports of the Philanthropic Societies “Charities”

• Passengers goods

• Returned Goods

− Returned goods of national origin

− Returned foreign goods

− For temporarily exported goods

• Diplomatic exemptions: Imports of the diplomatic corps, consulates, international organizations and the members of the diplomatic and consular corps

• Military exemptions: Imports for all sectors of the military forces and internal security forces

• Other types of exemptions

Goods exempted from customs duties

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Free Trade Agreements (“FTAs”)

GCC FTAs

• GAFTA: Greater Arab Free Trade Area

• GCC-Singapore FTA (Called GSFTA) entered into force on 2015

• EFTA - Free Trade Agreement between the GCC States and the European Free Trade Association (which comprises Switzerland, Norway, Iceland and Liechtenstein) entered into force on 1 July 2014.

• Other FTAs: Some GCC countries have signed bilateral free trade agreements (“FTA”) with other countries, such as the FTA between Bahrain and the US.

Note: To benefit from the preferential rates under those treaties, importers/exporters would need to satisfy the conditions and requirements set out in the relevant agreement

• Negotiations: Potential FTAs negotiated include Australia, China, India, EU, etc.

GCC overview

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GCC Import and VAT

Customs duty typically applies to the movement of goods from a country outside of the GCC to a country within

• Paid at the country of first import

• Free circulation of goods between GCC countries once entered for home consumption within the union (although note some variances in practice)

Import VAT typically applies to the movement of goods between countries; no ‘supply’ is required to be made

Expectation that an EU style model will be adopted in the GCC

• Import from third countries into the GCC

• Once goods are within the union, movements between may be out of scope for customs purposes (although there may be statistical reporting requirements)

What is a taxable importation

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GCC Import and VAT

Mechanics of customs duty

Classification

Global system for classification “Harmonised System”

Applied by all World Customs Organization members (and others)

Applied throughout the entire ME

Up to 8 digit level

Determines Import duty rate to be applied

Link with VAT-rate?

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GCC Import and VAT

Mechanics of customs duty determination

Valuation

Customs valuation is the value that is to be determined for the purpose of imposing import duties

Taxable basis for customs duties

NON-GCC country

1st border ME country (GCC)

Customer

Part of customs value

Not part of customs value

CIF first border

Meaning… this value must include all costs to the point of import, including commissions and brokerage, cost of containers, cost of packing, royalties and license fees, cost of international transport, cost of international insurance, etc.

But… is to be a value excluding certain other elements such as domestic transport

=> Not necessarily equal to the invoice value as such!!!

Customs value currently of limited / no relevance if a 0% import duty rate applies

=> Impact on / of import VAT?

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GCC Import and VAT

Mechanics of customs duty determination

• Non-preferential origin

• Preferential origin

− trading blocks

− bilateral agreements

• GCC status

=> Origin / GCC status impacts VAT treatment?

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GCC Import and VAT

It is typically the ‘importer of record’ who is required to pay any customs duty and import VAT

• Incoterms set out the rights and obligations between the parties on international goods movements

• Where a supplier sells on DDP incoterms it is liable for customs duty payable (in practice challenging for foreign suppliers)

GCC countries have licensing requirements and usually other legal requirements that must be met in order to import commercial shipments into the GCC

• Import activities should be reviewed to ensure that the importer of record is entitled to recover the import VAT charged (e.g. meets the business use test)

Who is required to pay….and receive any credit?

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GCC Import and VAT

Who is required to pay….and receive any credit?

BA

Commercial invoice

C

Commercial invoice

Physical flow of goods / “Pro-forma” invoice

Border

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GCC Import and VAT

Who is required to pay….and receive any credit?

BA

Commercial invoice

C

Physical flow of goods

Border

“Pro-forma” invoice / customs clearance

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GCC Import and VAT

Who is required to pay….and receive any credit?

BA

Commercial invoice

Physical flow of goods

A instructs and pays customs broker to import in the name of B and pays customs duties

Border

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GCC Import and VAT

Customs duty is payable to the local customs authorities prior to entering the goods for home consumption

Import VAT is typically due at the same time as customs duty payable

However, relief is commonly available in most VAT jurisdictions for VAT registered businesses, such as:

• Import deferral account (amount due is paid / recovered via entries on the VAT return so no cash flow impact)

• Import VAT is payable at the end of the month of import (cash flow impact limited to between payment and recovery via VAT return)

When is the payment due?

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GCC Export and VAT

An export for customs purposes typically applies to the movement of goods from a country within the GCC to a country outside the GCC

• Incoterm EXW (ex-works) – considerations for Customs and VAT purposes

What is an export?

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GCC Export and VAT

Customs: the entity that enters the goods for export

• Refer to Incoterms for responsibilities

For VAT purposes the position is less clear

• Likely the entity that arranges for the transportation

• May face challenges in meeting documentation requirements where flash title or back to back transactions occur before the goods are removed (e.g. back to back FOB transactions)

• May face challenges on indirect exports (supplier not responsible for transport across border)

Who makes the export?

B

A

Commercial invoice –with or without VAT?

Physical flow of goods

C

Commercial invoice –with or without VAT?

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GCC Export and VAT

Customs duty is not paid on export

As VAT is a tax on consumption, VAT would not typically be charged on supplies where the supplier is responsible for export…..however…

Documentation must be retained to evidence the removal of goods from the GCC

• Typically supplies default to taxable where no evidence to support exemption is retained

Penalties/Risks of non being compliant

• Risk of no proof of export – for VAT purposes may be perceived as taxable/local supply and therefore penalties could arise

• Globally and regionally customs authorities move towards data analytics – more likely in future such sources of information to trigger audits and higher risks

How much VAT and customs duty would be payable?

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GCC Law Duty Suspensions and Drawback

GCC Suspension Regimes and Free Zones

Goods in Transit Goods in transit are subject to the suspension of the customs duties and taxes applicable to all other kinds of transit transport, subject to conditions.

WarehousesGoods may be deposited within customs/bonded warehouses inside or outside the customs office without payment of customs duties and taxes, subject to conditions.

Free Zones & Duty free shopsForeign goods brought into the free zones and duty-free shops , and taken out from them to outside the country or to other free zone and duty-free shops, will not be subject to customs duties.

Temporary AdmissionGoods entering the GCC can be allowed to be placed under temporary admission for six renewable months with the suspension of the levied customs duties, subject to conditions

Re-exportation & Drawback Foreign goods imported into the GCC countries with a view to be re-exported shall be totally or partially refunded at re-exportation.

GCC Law and Implementation

Procedures

Warehouses

Free Zones &

Duty free

shops

Temporary Admission

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Overview of VAT in the GCC

VAT updates & timing hypothesis

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Introduction to tax reforms in the Middle East

Drivers for reform

Demographics

Planning for an education-hungry, older, future-state with long term illness a feature of longer lives

Growing need to fund healthcareobligations across age groups

Growing spending obligations

Limited existing capacity to generate revenues internally in the face of declining oil prices and uncertain demand

Existing fiscal challenges offer a ready mandate for change

Evolving realities

Hydrocarbon markets posing an ongoing revenue stability challenge

Accurate budgeting requires certainty over revenues and the ability to generate what is needed when it is needed

The current cash-funded balanced budget is not a long-term solution

Revenue stability

General trending towards convergence in the global tax environment

BEPS, CRS and transparency initiatives

Growing sense of moral obligation of MNC’s to embrace local tax obligations

International pressure

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No VAT, but other indirect taxes

GCC and VAT

OmanCustoms duties

Excise duties

Hotel /

restaurant taxes

UAE

Customs duties

Excise duties

Hotel/restaurant

taxesKSA

Customs duties

(with a number of

higher rates)

Excise duties

Hotel / restaurant

taxes

Qatar

Customs duties

Excise duties

Hotel /

restaurant taxes

Kuwait

Customs duties

Excise duties

Hotel/restaurant

taxes

BahrainCustoms duties

Excise duties

Hotel/restaurant

taxes

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Timing hypothesis

All countries to implement by 2019

All 6 countries

implement by

2019?

Planning is

ongoing

behind the

scenes

Remaining

GCC

countries

examine

impacts

Treaty

amended

domestic

leg. in prep

UAE, KSA

and Oman

implement

Kuwait,

Bahrain,

and Qatar

implement

Increasing

number of

statement

s of intent

issued

2016 ‘16 ‘18 ‘19

Remaining

countries

examine

current

need and

confirm

decisions

Although it is not clear when VAT will be implemented in all Gulf states, we can expect for

progress to be fast

We expect a staggered implementation

Where are we today?

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Relation between the Treaty and domestic legislation

The GCC and VAT

The GCC Treaty

• UAE

• Saudi Arabia

• Qatar

• Kuwait

• Bahrain

• Oman

• The GCC Treaty is now publicly available

• Sets the main VAT principles to be adopted within the GCC

• The VAT envisaged by the Treaty is relatively similar to EU’s VAT system

• It operates within the GCC Customs Union

Domestic Legislation

• Each individual country is now developing its own domestic legislation to implement the Treaty

• Within the leeway provided in the GCC VAT Treaty, the Member States may make a differentiation in designing their national VAT legislation

• A relatively short implementation period is expected across the GCC countries following the signing of the treaty.

• Returns, compliance, formalities etc. not harmonized

• Certain sectors likely to be granted preferred treatment (e.g. healthcare and transport)

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Four core features of VAT system :

• Broad-based tax on final household consumption – the burden of tax should not rest on business.

• Collected under a multi-staged process – VAT will be collected on “value added” at each stage throughout the supply chain

• Operated according to the “destination principle” – VAT should be levied at the location where the final household consumer is located.

• Tax neutrality – VAT should seek to be neutral and equitable to businesses. VAT should not hinder the formation of a business decision.

Based on the International VAT/GST Guidelines published by OECD

Design of VAT in the GCC

Design principles

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• UAE, Oman and KSA target 1 January 2018

• Bahrain expected to implement in mid 2018

• Qatar and Kuwait lag further behind

• KSA has published its draft VAT law on 29 May 2017 for consultation and comments.

• Federal VAT law and the VAT Executive Regulations in the UAE are expected to bepublished in Q3 2017 setting out the application of VAT within the UAE.

• Federal Tax Procedures Law in the UAE will govern the general rules and proceduresrelating to VAT and other taxes within the UAE – expected to be published in the comingweeks

• VAT registration in the UAE will be opened during Q3 2017 on a voluntary basis and Q42017 on a compulsory basis

VAT Updates

Announcements to date

Much still needs to be defined but time is short !

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Overview of VAT in the GCC

VAT fundamentals

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VAT works in the GCC like in most jurisdictions

VAT Mechanics

Outputs

• A business makes ‘supplies’ of goods and servicesto a recipient

• Output tax normally due on these supplies (unlessexempt, zero-rated or “outside the scope”)

• Business charges VAT on the supplies (usuallyadds it to the price) and accounts for the VAT bypaying it to the authorities

Inputs

• VAT charged to a business on purchases andimports of goods and services

• Paid to the supplier as part of the purchase price(price includes VAT)

• VAT incurred for business purposes is input tax andis recoverable if it has been incurred in the courseof making taxable supplies

• Evidence is required to claim input tax

VAT recoverable

from customers

Payable to the Tax

Authority

VAT payable on business purchases

Net VAT

Output tax > Input tax

Less

Refundable by the Tax Authority

Output tax < Input tax

Equals

Output tax

collected

Input tax credits

(ITCs) for VAT paid

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RegistrationWho must register

Every taxable person (a company, natural person, or other) resident of a Member State

Annual supplies in the Member State exceeds or is expected to exceed the mandatory registration threshold

This taxable person is conducting an economic activity independently in a permanent manner.

• Supplies made in the current month and previous 11 months; or

• Projected supplies of the current month and the subsequent 11 months

• Excluding exempt supplies

Calculation of the value of annual supplies

187,500

375,000

Voluntary registration

threshold (SAR)

Mandatory registration

threshold (SAR)

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RegistrationWho must register (cont’d)

• Supplies made in the current month and previous 11 months; or

• Projected supplies of the current month and the subsequent 11 months

• Excluding exempt supplies

Calculation of the value of annual supplies

No threshold applies to non established taxable persons – they may be required to register

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• Transaction not a supply of goods = supply of services.

• Income which does not qualify is out of scope of VAT (e.g. dividends)

• Output transactions = transactions made by the taxable person = Output VAT on supplies of goods and services

• Input transactions = transactions made to the taxable person = Input VAT on purchases of goods and services, as well as imports

There are only 3 types of transactions potentially subject to VAT: supplies of goods, services and imports

What transactions will be subject to VAT in the GCC

Taxable supplies of goods or services made by a taxable person

Supply of goods / services

1. Made for consideration

2. In a GCC member country

3. A taxable supply (i.e. 5% or 0%)

4. Made by a taxable person

Importation

Import of goods by any person into the GCC from outside the GCC

Supplies of goods & services

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Place of supplyWhere the supply is taxed

• Is the supply taxable in the GCC?

• Which GCC Member State can tax?

• Determines the Member State in which the supply will be taxed and VAT payable

• If place of supply outside GCC Member State supply not subject to GCC VAT (but perhaps subject to local VAT)

• Taxable persons (also the ones merely making exempt supplies) need to pay VAT on goods and services received

?

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Place of supplyWhere will the supply be taxed – General rules

Goods

Gas,oil, water and electricity

Services

• Taxable supply = supply of goods or services

• Supply is not supply of goods = a service

Goods Services

No delivery where goods are placed at customer’s disposal

Delivery to GCC B2B customer

Member State of final destination

Other deliveries

Member State of dispatch

B2B services Location of the customer

B2C services Location of the supplier

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Place of supplySpecial rules for services

Transportation lease servicesLocation where transportation means were placed at customer’s disposal [Article 17; GCC VAT Agreement]

02

01Telecommunication and electronically supplied services Location where services are used or enjoyed [Article 20; GCC VAT Agreement]

04

03

05Real estate related services location of the real estate property [Article 18; GCC VAT Agreement]

Restaurants, hotel and events related services Location where services are performed [Article 21; GCC VAT Agreement]

Passenger transportation servicesLocation where transportation begins [Article 19; GCC VAT Agreement]

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Place of supplySpecial rules goods

Goods

Gas,

Note: special rules for cross-border B2C supplies, water and electricity

Services

• Supply of gas, oil, water and electricity from one member state to

• a taxable trader in another member state

taxed at the location of the customer

• other recipients in another member state the location of consumption

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Supplies within scope of VATZero-rated or exempt?

Medicine and medical equipment

Cross-border goods and passenger transportation services

Goods exported outside GCC territory

Certain cross-border supplies of services for non GCC recipients

Certain transactions in gold, silver and platinum

Certain food items

Supply of means of transportation for commercial purposes

Oil, oil derivatives and gas sector

Education sector

Healthcare sector

Real estate sector

Local transport sector

Financial services (with some flexibility to tax)

Importation, if the goods are

• exempted or zero-rated in the country of importation

• exempted from customs

Must zero-rate01 May zero-rate02 May either exempt or zero-rate

03 Must exempt04

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Types of supply and rates applicable

Supplies of goods & services

• VAT will be charged at a standard rate of 5% unless the goods or services are

• Exempt

• Zero-rated

Difference in Input Tax treatment

• Specific goods or services can be zero-rated (exemption with right to deduct input VAT) or exempted

• Specific goods or services are compulsory exempt or zero-rated

Exempt

Zero-rated

5%

• Zero-rated goods or services: allows input VAT recovery in relation to purchases

• Exempt goods or services: input VAT recovery in relation to purchases notallowed

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Date of removal of goodssupply with transportation

Date goods made available to customer supply without transportation

Performance of service complete

Override if before that :– Tax invoice is issued– Payment is received

Time of supplyWhen to account for output VAT on supplies

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VAT liabilityWho pays VAT to the State? - Imports

• Import: Importer of record

• VAT paid by filing the import declaration

• Import declaration allows the input VAT recovery

• Special license to defer payment of import VAT: Potential option not to pay import VAT in the import declaration but in the periodical VAT return

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VAT liabilityWho pays VAT to the State? Other supplies

• Who needs to pay a receivable!

• Supplier is liable for the payment of VAT to the State

− Exception: Reverse charge customers pays the VAT

− Supplier is not resident

− Customer is a business

− Shift in liability – customer pays the VAT in tax return instead of the supplier

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VAT liabilityWho pays VAT to the State?

• Who needs to pay a receivable!

• By default the supplier is liable for the payment of VAT to the UAE on all supplies of goods and services which take place in the UAE

Exception: Reverse charge Customers pays the VAT

− Supplier is not resident

− Customer is a business

− Shift in liability – customer pays the VAT in tax return instead of the supplier

− Advantageous from a cash flow perspective

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Free zones: Treatment of supplies made to and from free-zones

• Especially important for the UAE

• No comment on VAT treatment of supplies between free-zones and other areas

• It is possible that a difference will be made between fenced and non-fenced (i.e. financial such as the DIFC) free-zones, with the latter not being treated as a free-zone for VAT purposes

• However, whether or not this will be the case is still to be confirmed by the local VAT legislations

• Potential distinction for the non fenced free-zones between the types of supply

• As the current free-zone agreements indicate that the areas are fully exempt from taxes and will remain as such at least for a certain number of years, it is likely that the agreements must be revisited in terms of the applicable VAT treatment

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VAT fundamentals

Other issues

• VAT returns submitted periodically together with payment

‒ Usually three months or monthly (quarterly in UAE)

• VAT return submission and payment determined country by country

• Electronic VAT return submission and payment possible (or even compulsory - UAE) in most countries

• Additional reporting requirements could arise for intra-GCC trade and trading between Emirates

• Incorrect, incomplete or missing VAT returns = Tax authority estimation

• Penalties for errors or failure to file and/or pay likely, and likely to be significant

Errors and penalties

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GCC VAT vs. the EU VAT

directive

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GCC VAT

Comparing transactions to the EU directive

• Business sells goods to another business

• Customer is established in other GCC MS

• Goods are transported from one MS to another

Supplies of goods from one MS to

another

• Intra-community supply exempt in MS of dispatch if all conditions are met

− Proof of transport and capacity customer

− VAT return

− ESL

• Taxed intra-community acquisition in MS of arrival

• Supply taxed in the MS of arrival

− Proof of transport and capacity customer

− VAT return

− No ESL but ESS (still to be set up!)

• Reverse charged by the customer

• Certain customs formalities (statistical declaration) / additional duty payment

EU GCC

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GCC VAT

Comparing transactions to the EU directive (cont’d)

• Business provides general services to another business

• Customer is established in other GCC MS

Supplies of services from one

MS to another

• B2B supply of services

− Capacity customer

− VAT return

− ESL

• Located in MS customer

• Reverse charged by customer

• B2B supply of services

− Capacity customer

− VAT return

− No ESL but ESS (still to be set up!)

• Located in MS customer

• Reverse charged by the customer

EU GCC

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GCC VAT

Comparing transactions to the EU directive (cont’d)

• Business makes a supply of goods or services

• To a customer registered for VAT

• The customer is established in the MS where the supply takes place

Reverse charge

• Domestic supply

− VAT return

• Option in article 194 VAT directive to R/C

− When customer has VAT number (FR)

− When customer has VAT number AND is registered (NL and partly BE)

− No R/C (DE for certain supplies)

• Reverse charged by customer

• Domestic supply

− VAT return

• Obligation to apply a reverse charge when customer has VAT number AND is registered

• Reverse charged by customer

EU GCC

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Deloitte approach to

implementation

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5 phased approach

Deloitte approach to implementation

1.5 Response strategy

1.6 Roadmap

1.4 VAT impact summary report

Our

delivera

ble

s

1.2 Impact Workshops

1.3 Transaction mapping

1.1 Kick-off meeting

Key o

bje

ctive

2.4 BusinessRequirements

2.5 Fit-gap analysis

2.6 IT Solution design

3.5 Communication

3.6 Migration

3.4 VAT Processes

3.2 IT Configuration

3.3 Document templates

3.1 IT Technical design

4.3 Training

4.4 VAT governance

4.1 Testing

2.2 VAT technical guide

2.3 Approach authorities

5.3 Overall VAT assessment

5.1 Post go-live IT support

5.2 Review first VAT return

PMO

4.2 VAT technical support

• Snapshot of the business and current VAT state

• Identify the impact of VAT on the business

• Develop a Roadmap

4.5 Go-live support

• Determine to-be state

• Gather legal and regulatory requirements

• Determine fit-gap to meet VAT day 1 compliance

• Building of the solution design for IT

• Development of processes and templates

• Migrate Master Data

• Training and Knowledge transfer to the end-users

• Testing of implemented changes and processes

• Communicate changes

• Finalize implementation design

• Review after first VAT return

• IT support during transition phase

1. Assessment &Roadmap

2. Design 3. Implement 4. Test & Train 5. Post go-live

3.7 VAT registration

2.1 Project Plan

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Deloitte Survey

The Malaysian experience in hindsight

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Deloitte Survey

The Malaysian experience in hindsight (cont’d)

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IT systems

Lessons learnt from other systems implementations

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Learn the 5 W’s

Tax and technology

The ‘W’ VAT expert VAT calculation engine

Who? • Who is the supplier, and who is the customer?• Are either party, or both parties registered?• Is the supplier or customer overseas?• Is it in the course or furtherance of a

business?

• Customer master data (e.g. VAT#)

• Supplier master data (e.g. VAT#)

What? • Is this a supply of goods or services?• Is this one supply, or multiple supplies?

• Item master data

Where? • The place where the supply is deemed to take place determines which jurisdiction’s VAT laws apply and the VAT liability applicable (e.g. standard, reduced or exempt)

• Customer master data - locations• Supplier master data – locations• Logistics data – ship to/ship from

When? • When do I need to account for the VAT and/or recover the VAT as the case may be?

• In either case, what documentation do I need to satisfy the authorities?

• System information dates such as invoice date, service date, payment date, delivery date

(W)howmuch?

• The value question – VAT is determined by reference to the value of the supply, the nature of the supply and the rate applicable to it

• Invoice amount/transaction value

1

3

4

5

2

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Tax and Technology

• Globalization, Regulation and Business Complexity increases force on tax departments

• Automated tax disclosures and audits.

• Gap between company ERP data and governments is closing. Tax departments require technology adoption much more today then before.

• Become a stronger Partner to the broader business and IT.

• ERP Challenges: Master Data, Process excellence and IT infrastructure.

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This document has been prepared by Deloitte LLP for the sole purpose of providing a proposal to the parties to whom it is

addressed in order that they may evaluate the capabilities of Deloitte LLP to supply the proposed services.

The information contained in this document has been compiled by Deloitte LLP and includes material which may have been

obtained from information provided by various sources and discussions with your management which has not been verified

or audited. This document also contains material proprietary to Deloitte LLP. Except in the general context of evaluating our

capabilities, no reliance may be placed for any purposes whatsoever on the contents of this document or on its

completeness. No representation or warranty, express or implied, is given and no responsibility or liability is or will be

accepted by or on behalf of Deloitte LLP or by any of its partners, members, employees, agents or any other person as to

the accuracy, completeness or correctness of the information contained in this document or any other oral information

made available and any such liability is expressly disclaimed.

Other than as stated below, this document and its contents are confidential and prepared solely for your information, and

may not be reproduced, redistributed or passed on, directly or indirectly, to any other person in whole or in part. Therefore

you should not refer to or use our name or this document for any other purpose, disclose them or refer to them in any

prospectus or other document, or make them available or communicate them to any other party. If this document contains

details of an arrangement that could result in a tax or National Insurance saving, no such conditions of confidentiality apply

to details of that arrangement (for example, for the purpose of discussion with tax authorities). In any event, no other party

is entitled to rely on our documentation for any purpose whatsoever and thus we accept no liability to any other party who

is shown or gains access to this document.

This document is not an offer and is not intended to be contractually binding. Should this proposal be acceptable to you,

and following the conclusion of our internal acceptance procedures, we would be pleased to discuss terms and conditions

with you prior to our appointment.

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”),

its network of member firms, and their related entities. DTTL and each of its member firms are legally separate and

independent entities. DTTL (also referred to as “Deloitte Global”) does not provide services to clients. Please see

www.deloitte.com/about for a more detailed description of DTTL and its member firms.

Deloitte & Touche (M.E.) is a member firm of Deloitte Touche Tohmatsu Limited (DTTL) and is a leading professional

services firm established in the Middle East region with uninterrupted presence since 1926.

© 2017 Deloitte & Touche (M.E.). All rights reserved.

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Annex:

Our strengths, capabilities and credentials

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Your VAT implementation team at Deloitte ME

Our strengths and capabilities

Subject Matter Experts

• VAT implementation experts with recent implementation experience in Malaysia and other countries (Singapore, South Africa, Australia etc.).

Industry focused

• Our team includes a range of industry experts and can assist JC in identifying industry specific impacts

Bespoke Project Design

• We recognize that no two businesses are the same and we are adaptive to your specific demands, ready to respond to any unforeseen challenges that may arise

Cross-service line delivery

• Large scale VAT implementation projects involve a number of disciplines requiring specialists in Technology, Human Capital and Project Management, in addition to VAT and our team understands well how each discipline should interact for your benefit.

Underpinned by enablers

Deloitte has developed a number of unique tools, “enablers”, that are especially desirable for large businesses providing time & resource efficiencies and allowing for benchmarking

OUR TEAM

APPROACH

Our value proposition

Our team

Our approach

Policy Makers

• Our VAT policy team has been at the forefront of VAT in the region since the beginning of the decade.

• We are advising two of the GCC Member States in drafting their national VAT laws.

Deloitte Indirect Tax in the GCC

• Over 50 VAT specialists (including VAT implementation specialists)

• Headquartered in Dubai

• Covering the 6 GCC Member States

Knowledge Transfer

• We deliver a project designed to ensure you will be compliant at the introduction of VAT & afterwards.

• We ensure that our clients build their VAT understanding and develop VAT controls and processes as appropriate.

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Johan Van Der Paal – VAT Partner

Johan Van Der Paal is an indirect tax partner with Deloitte Belgium, based in Brussels. Johan has more than 20 years of experience as an advisor in indirect taxes, with a focus on VAT. He developed a focus on tax matters affecting the financial services and energy & utilities industries.

Johan has been assisting many larger insurance and banking clients in Belgium setting up and operating cost sharing or VAT grouping arrangements. He also leads Deloitte’s international team on VAT studies for the European Commission.

Johan is Professor at the Ghent University, teaching VAT, since 2015. He is a regular speaker at internal and external seminars. He is regularly consulted in his expertise domain by professional federations in Belgium on legislative initiatives and is member of the VAT Expert Group set up by the European Commission.

Johan Van Der PaalPartnerDeloitte [email protected]+32 475 90 56 69

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Thomas Vanhee – VAT Senior Manager

Thomas is a Senior Manager in the Middle East Indirect TaxPractice of Deloitte and has specialized in indirect tax foraround ten years.

Thomas works for a large variety of businesses, private clientsand institutions. He has experience in very high profile M&Adeals and has succesfully assisted the financial and non-profitsector in improving their VAT recovery.

Thomas was also exposed to French VAT during the time heworked in Paris, and is involved with VAT policy work with theEuropean institutions and GCC governments.

He is also a member of IFA and lectures at Solvay BusinessSchool. He speaks English, Dutch, French, Portuguese andSpanish.

Thomas VanheeSenior ManagerDeloitte [email protected]+971 58 263 3018

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Fernand Rutten – Customs and Global Trade Leader

Fernand Rutten is the Deloitte Global Customs and Global Trade Leader and Managing Partner of the Customs and Global Trade service line of Deloitte Belgium.

Fernand has over 20 years of experience in indirect tax, with a strong focus on customs, excises and global trade matters. Before becoming a consultant, he worked as a customs official with the Dutch customs authorities dealing with several customs and global trade matters, issuing rulings on customs valuation and customs economic procedures.

Some 17 years ago, Fernand became a customs and global trade consultant. He further specialized in a variety of customs and global trade matters and built out a specialized of experts serving clients in both the public and private sectors in business model optimization, automation, compliance, export controls, excises, litigation, valuation, origin, classification, and data analytics. In leading the Belgian customs and global trade service line, Fernand has advised clients on customs and global trade matters in many domains.

Fernand RuttenPartner Deloitte [email protected] +32 (0) 496 57 49 66

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Daan De Vlieger – Customs and Global Trade Senior Manager

Daan is member of the Deloitte EMEA Customs & Global TradeCentre of Excellence since 2008.

Currently holding the position of Senior Manager, he servesvarious clients in the customs, trade compliance and excisedomain across the globe. Countries and regions of activitycover a.o. the Middle East region, the European Union,Switzerland, the United states, etc.

Current and past client include both public and private sectorbodies and entities.

Content-wise, focus areas are a.o. customs classification, originand valuation; customs import and export procedures, exciseprocedures, excise categorization, excise exemptions andmovement regimes, customs and excise management, customsand trade compliance, Free Trade Agreements, WTO traderegulations, Incoterms, etc.

Daan De VliegerSenior Manager Deloitte [email protected]+32 (0)478 90 87 51

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Frederik Drappier – Senior Manager Indirect Tax Technology

Frederik Drappier is a Senior Manager within Deloitte Tax inBelgium where he applies his technology integration skills to alltax and regulatory topics.

He has been involved since 2002 in numerous large businesstransformation and integration projects specialized inoptimizing and streamlining transaction flows, improvingindirect tax and statistical reporting as well as pan-Europeancompliance of global organizations.

Frederik has extensive experience in different industriesincluding Financial Services, Public Sector, Communications,Industrial Manufacturing and Life sciences and Healthcare.

Frederik DrappierSenior Manager Deloitte [email protected]+32 (0)496 926 16 64