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CONTENTS 
▶▶BELGIUM 
Warehousing services: Belgium brings 
its interpretation in line with the 
EU implementing regulation 1 
▶▶EDITOR’S LETTER 2 
▶▶ECUADOR 
Value Added Tax (VAT) on import of 
services 2 
▶▶IRELAND 
Adjustment of tax deductible in relation 
to unpaid consideration 3 
▶▶ISRAEL 
Israeli and U.S. Customs authorities sign 
AEO mutual recognition agreement 3 
▶▶LATVIA 
Recommendations for the assessment 
of counterparty and transaction risks 3 
▶▶ROMANIA 
European Court of Justice ruling on 
Romanian authorities’ treatment of 
financial leases on termination of lease 4 
▶▶SPAIN 
Bill amending Spain’s VAT law 4 
▶▶UGANDA 
The legality of the imposition of 
domestic VAT on imports of goods 
into Uganda challenged 5 
ECUADOR 
VAT on import of services 
READ MORE 2 
ISRAEL 
Israeli and U.S. customs authorities sign 
AEO mutual recognition agreement 
READ MORE 3 
SEPTEMBER 2014 ISSUE 3 
WWW.BDOINTERNATIONAL.COM 
INDIRECT TAX NEWS 
BELGIUM 
WAREHOUSING SERVICES: BELGIUM BRINGS ITS INTERPRETATION IN LINE 
WITH THE EU IMPLEMENTING REGULATION 
With effect from 1 June 2014, the Belgian tax 
authorities have changed the place of supply 
rules, and hence the liability to Belgian VAT, for 
the provision of warehousing facilities. 
When the EU’s place of supply rules 
were rewritten in 2010, the Belgian 
VAT authorities initially considered 
warehousing services to be services connected 
with immovable property, as referred to in 
article 47 of Directive 2006/112/EC. 
However, as this point of view was not in line 
with some of the other EU Member States, it 
was temporarily allowed to apply the general 
B2B place of supply rules. 
From June 2014, this has changed. Belgium’s 
new rules now specify which warehousing 
services are connected with immovable 
property and which are not. This is believed 
to be in response to the European Court 
judgment in the C-155/12 RR Donnelley case 
last year, and in anticipation of Council 
Implementing Regulation no. 1042/2013, 
which becomes binding in all EU Member 
States in 2017. 
The new rules outline the VAT treatment of 
three situations: 
Exclusive use 
Where warehousing facilities are provided 
for the “Exclusive use” of the foreign 
trader, this is now considered a supply of 
immovable property as per article 47 of 
Directive 2006/112/EC. This implies that 
Belgian VAT is, in principle, due (at the 
standard rate of 21%) on such services 
provided in a warehouse located in Belgium, 
regardless of where the service provider and/or 
the recipient are established. 
Article 31a, 2(h) of the Implementing 
Regulation states that “Services connected 
with immovable property, as referred to 
in Article 47 of Directive 2006/112/EC, 
shall include only those services that have 
a sufficiently direct connection with that 
property [...] including the storage of goods 
for which a specific part of the property 
is assigned for the exclusive use of the 
customer.” 
Facilities are deemed to be for “Exclusive use” 
if all of the following conditions are met: 
• The exclusive use must be assigned to the 
service recipient for the entire period of the 
agreement; 
• The service recipient is entitled to freely 
access its goods in the warehouse, 
irrespective of the fact that the warehouse 
owner provides some kind of security; 
• The agreement must explicitly determine 
the location of the warehouse or the area 
within the warehouse where the goods will 
be stored; 
• The goods must be identifiable; 
• The service provider cannot change the 
actual place of storage of the goods within 
the warehouse without consent of the 
owner of the goods; 
• The service recipient must be able to 
exclude any other person from the use of 
the locations attributed to the recipient, 
and use this at the recipient’s discretion; the 
owner of the warehouse is not entitled to 
render any additional services regarding to 
the stored goods. 
ROMANIA 
ECJ ruling on Romanian authorities’ treatment 
of financial leases on termination of lease 
READ MORE 4
2 INDIRECT TAX NEWS 3 
EDITOR’S 
LETTER 
Dear Readers, 
Greetings from Barcelona where I’m 
currently transiting en route home 
to Dublin from Madrid where I 
hosted BDO’s International VAT & Customs 
conference for 2014. This year’s conference 
was attended by 86 delegates from 
34 Countries including the US, Canada, 
South Africa, India, the Dominican Republic, 
Israel and European countries from both 
within and outside the European Union. 
This event, attended by Partners and Senior 
Management who are all full time Indirect 
Tax experts, was our largest Conference 
ever, surpassing last year’s attendance in 
Dublin by over 33%. 
It was also the first time that we have 
had a Customs & International Trade 
focused forum running in tandem with our 
mainstream VAT focused event, which 
enabled all delegates to get together on 
the first morning and last afternoon of the 
event. 
I am very proud of the progress that I and 
my colleagues at the BDO International 
VAT Centre of Excellence have made 
(assisted, of courses, by the leaders of our 
APAC and Customs sub-groups) over the 
three years since I initially became Chair. 
Hopefully it is a source of comfort to you 
knowing that BDO continues to improve 
its capacity and that we continue to ensure 
we have the highest standards to meet the 
ever increasing demands for both domestic 
and international guidance and leadership 
on indirect tax related issues. 
I hope you will find this edition of ITN a 
useful source of information and many 
thanks, as always, to Sarah Halsted our 
editor, our contributors from around 
the globe, and our colleagues at the 
BDO International Office who provide 
background assistance to us. 
Kind regards from Dublin. 
IVOR FEERICK 
Chair – BDO International VAT Centre of 
Excellence Committee 
Ireland – Dublin 
ifeerick@bdo.ie 
Non-exclusive use 
Where the foreign trader does not have 
exclusive access because other traders may 
rent the facility too, then the general B2B and 
B2C rules apply. 
In general this will be the case if one or more 
of the previously mentioned criteria are 
not met, for example if there is no specific 
warehouse (or part of a warehouse) designated 
for the goods to be stored at, or if the owner 
does not have access to the stored goods. 
Additional warehousing services 
If warehousing services are rendered along 
with other services related to the storage of 
goods, this transaction no longer qualifies 
as the mere letting of storage space. Under 
agreements that do not grant an exclusive use 
and/or the warehouse owner renders a set of 
services (in order to maintain or improve the 
quality of the goods) of which the warehouse 
service is only a part, the link with the 
warehousing services is less direct. In this case, 
the general B2B or B2C place of supply rules 
apply. 
KAATJE BONDEWEL 
Belgium – Brussels 
kaatje.bondewel@bdo.be 
ECUADOR 
VALUE ADDED TAX (VAT) ON 
IMPORT OF SERVICES 
Value Added Tax (VAT) is levied in 
Ecuador on the transfer of ownership 
and importation of goods and services 
at all stages of manufacture, as well as on 
copyrights, industrial property, and related 
rights. 
In the case of services imported into Ecuador, 
the tax law specifies that they are subject to 
VAT at 12%. VAT paid on imported services 
can be deducted from VAT the importer 
generates on its sales. In other words, the 
taxpayer in Ecuador can reduce the VAT it 
must pay to the tax authorities by the amount 
of VAT it pays on imported services. 
In order to qualify for this deduction, 
the services must meet the following 
requirements: 
• The service provider must be domiciled 
abroad and must provide a proper invoice 
that shows, in detail, the service provided, 
the price charged for the service, and 
identification of the buyer (the taxpayer in 
Ecuador). 
• The taxpayer in Ecuador must issue a 
document authorised by the tax authorities 
called “Liquidación de Compras de bienes 
y prestación de servicios”. This document 
must show the VAT rate of 12% separate 
from the total cost of the imported services. 
VAT generated on the importation of services 
is subject to 100% withholding and must 
be paid to the Ecuadoran tax authorities by 
the importer of the services in the month 
following the registered date of the invoice in 
the accounting books of the taxpayer. 
VERONICA PEÑA 
Ecuador – Quito 
vpena@advice.com.ec
INDIRECT TAX NEWS 3 3 
IRELAND 
ADJUSTMENT OF TAX DEDUCTIBLE 
IN RELATION TO UNPAID 
CONSIDERATION 
ISRAEL 
ISRAELI AND U.S. CUSTOMS 
AUTHORITIES SIGN AEO MUTUAL 
RECOGNITION AGREEMENT 
LATVIA 
RECOMMENDATIONS FOR THE 
ASSESSMENT OF COUNTERPARTY 
AND TRANSACTION RISKS 
Introduction The Finance (No. 2) Act 2013 introduced 
Section 62A to the VAT Consolidation 
Act 2010. This new Section provides 
for adjustments to be made in respect of tax 
deductible in relation to unpaid consideration. 
In simple terms, this means that where a 
taxable person has claimed a VAT deduction 
in a taxable period (referred to as the 
“initial period”) on a valid VAT invoice received 
from a supplier but the taxable person has 
not paid the supplier for the related goods or 
services within six months, that person must 
repay to Revenue the amount of input credit 
originally claimed. 
This provision was introduced with effect 
from 1 January 2014. As a result, the 
consideration in respect of invoices on 
which VAT was reclaimed in the January/ 
February 2014 VAT return must be paid 
no later than 31 August 2014, the last day 
of the sixth month following the initial 
period. Consequently, the July/August 2014 
VAT return will be the first return that an 
adjustment in respect of unpaid consideration 
may arise. 
Similarly, an adjustment must be made where 
only part payment is made in satisfaction 
of the debt. In such cases an adjustment is 
required to be made in respect of the amount 
of the invoice that remains unpaid. 
Where a taxpayer has made a full or partial 
adjustment but subsequently makes a 
payment to the supplier, the taxpayer can 
claim the input credit in its VAT return for the 
period in which the payment is made. 
Grounds for not making an adjustment 
The Revenue Commissioners accept that 
there may be instances where an adjustment 
is not required and Revenue has issued 
some guidance in this regard. The guidelines 
relate to situations where there are genuine 
commercial reasons why the taxpayer has 
made no payment or only partial payment to 
the supplier. 
JIMMY RYNHART 
Ireland – Dublin 
jrynhart@bdo.ie 
In June 2014 a mutual recognition 
agreement was signed by the Israeli 
Customs authority and the U.S.’s Customs 
and Border Protection. The agreement 
acknowledges each other’s approvals 
process for “Authorised Economic Operator” 
programs for the purpose of customs 
mutual simplifications and facilitation (the 
US program is known as “C-TPAT”, which 
stands for Customs Trade Partnership against 
Terrorism). Mutual recognition helps facilitate 
trade between the two countries because it 
reduces the need for security and customs 
inspections of authorised exporters from one 
country by the customs authority of the other 
country. 
An authorised economic operator (or 
“authorised operator”) is a trader that has 
been examined by the customs authorities 
of one of the two countries and has been 
found to satisfy certain requirements and 
criteria, such as security, customs compliance, 
compliance with tax and trade rules and 
regulations, financial strength, appropriate 
computerised systems, documentary controls, 
inventory controls, a proper plan for recovery 
from catastrophic incident, and so on. 
Authorised operators will enjoy simplified 
process regarding their international trading, 
including: a lower level of customs checking 
and procedural requirements that will save 
them time and costs, including, for example, 
the possibility of having documents examined 
before the arrival of the Imported goods, and 
so on. 
The Authorised Economic Operator program 
of the Israeli Tax Authority is based on the 
SAFE Framework of Standards of the World 
Customs Organisation. As part of this 
program, unified standards for the security, 
compliance, and financial viability of the 
global supply chain were introduced. The 
program is based on voluntary participation 
of companies (including importers, exporters, 
intermediaries, carriers, terminal operators, 
distributors and so on) that are willing 
to adopt the SAFE framework for trade 
facilitation and global supply chain security. 
As of today, Israel has signed mutual 
recognition agreements with the American 
and Taiwan authorities and it is in the process 
of negotiating such an agreement with South 
Korea and other countries. 
AYELET YITZHAKI 
Israel – Tel Aviv 
ayelety@bdo.co.il 
In daily operations, companies are exposed 
to the risk of being involved in fraudulent 
transactions. Companies that are involved 
in such transactions can lose the right to 
claim deductions in Latvia for input VAT. To 
minimise the chances of being involved in 
such transactions, taxpayers should conduct 
reliability assessments of counterparties they 
deal with. 
There are two requirements under the Latvian 
VAT Act that taxpayers must comply with to 
recover input VAT: 
1. The taxpayer must check to see whether the 
counterparty is registered in the Latvian VAT 
register; and 
2. If the counterparty is from another Member 
State, the taxpayer must check to see if the 
counterparty has a valid VAT number. 
The Latvian State Revenue Service (SRS) 
recommends that taxpayers get evidence 
on counterparties’ reliability themselves. 
Unfortunately, it is not always possible for 
taxpayers to obtain all the information about a 
counterparty (for example, whether a business 
unit is registered with SRS, whether it uses the 
assets in its possession for business activities, 
and so on). As a result, taxpayers are exposed 
to a certain amount of risk. 
To help taxpayers protect their right to recover 
input VAT, the Latvian SRS recently issued 
recommendations regarding assessment of a 
counterparty and the risk of a transaction. The 
recommendations are based on the guidance 
developed by the United Kingdom. 
The recommendations outline the steps 
taxpayers should take to assess reliability 
of a counterparty. For example, the SRS 
recommends that taxpayers look for publicly 
available information on counterparties 
– things like registration data, licenses 
and permits issued to the counterparty, 
information about the counterparty’s 
financial position (such as liabilities, 
insolvency proceedings, and so on), and 
the operational results of the counterparty. 
It is worth emphasising, however, that 
the recommendations are for information 
purposes only and are not binding on 
taxpayers. 
INITA SKRODERE 
GITA AVOTINA 
Latvia – Riga 
inita.skrodere@bdotax.lv 
gita.avotina@bdotax.lv
4 INDIRECT TAX NEWS 3 
ROMANIA 
EUROPEAN COURT OF JUSTICE RULING ON ROMANIAN AUTHORITIES’ 
TREATMENT OF FINANCIAL LEASES ON TERMINATION OF LEASE 
The European Court of Justice’s opinion 
was sought in the Romanian case of BCR 
Leasing IFN SA vs. National Agency for 
Fiscal Administration (ANAF)-DGAMC & DGSC 
with the payment of value added tax on goods 
leased under a financial leasing contract but 
deemed missing after not being returned to the 
leasing company. 
BCR Leasing (BCR) is a limited company whose 
main activity is financial leasing. It acquires 
cars from various suppliers and fully deducts 
the input VAT paid on these purchases. After 
acquiring the cars, the company enters into 
financial leasing contracts with natural and 
legal persons who then use the vehicles for the 
term of the contract. BCR remains the owner 
of the cars. As a result of late or non-payment 
under the leases, BCR terminated some of the 
contracts it had with defaulting lessees. Since 
BCR did not receive payments in respect of 
the terminated contracts, BCR stopped issuing 
invoices relating to those contracts and it 
stopped collecting the corresponding VAT. 
During an audit carried out in 2011, the tax 
authorities found irregularities relating to the 
manner in which BCR indicated, recorded, 
and declared VAT for the period from 
1 September 2008 through 31 December 2010. 
By notice of 30 August 2011 and a tax 
audit report of the same date, the tax 
authorities imposed an additional payment 
of RON 19,266,551 on BCR in respect of VAT, 
as well as a penalty of RON 9,502,774 for 
delayed payment. 
The tax authorities took the position that for 
the entire term of a financial lease the lease 
must be treated as a supply of services and, 
depending on whether the lessee exercises an 
option to purchase the vehicle, there may be 
a supply of goods on expiry of the contract. 
According to the tax authorities, if the goods 
are vehicles that are returned to BSR at the 
end of the financial lease, BSR is required to 
apply the provisions of the Romanian Fiscal 
Code on self-supplies and must collection VAT 
and must issue invoices to itself in respect of 
those supplies. 
BSR argued that the national legislation the 
tax authorities relied on is not compatible with 
the system introduced by the VAT Directive. 
As a result, BCR filed an action for the 
annulment of the tax notice. The Bucharest 
Court of appeal recently heard the case. 
Because of the possible conflict between 
the Romanian tax authorities’ interpretation 
and the VAT Directive, the ECJ was asked to 
determine: 
• Whether a leasing company could 
be considered to supply goods for 
consideration within the meaning of 
article 16 of Directive 2016/112/EC in which 
the lease terminated as a result of the 
lessee’s breach of the terms of the lease 
and the lessor has followed the statutory 
procedures for recovery but did not recover 
anything from the lessee. Or, 
• Whether there might there be a supply of 
goods for consideration within the meaning 
of Article 18 of Directive 2006/112/EC. 
The ECJ ruled (Judgment C-438/13) that 
Articles 16 and 18 of Directive 2006/112/EC 
must be interpreted as meaning that there has 
not been a supply of goods for consideration 
for the purposes of the Directive if a leasing 
company cannot recover from the lessee 
following termination as a result of the lessee’s 
breach and therefore BCR should not be 
required to collect VAT for unrecovered goods 
from the lessees. 
DAN BARASCU 
HORIA MATEI 
Romania – Bucharest 
dan.barascu@bdo.ro 
horia.matei@bdo.ro 
SPAIN 
BILL AMENDING SPAIN’S VAT LAW 
On 6 August 2014 a proposed bill 
amending various provisions of 
Spain’s VAT law was published in the 
Houses Official Journal. 
The provisions of the bill can be categorised 
into three groups: 
1. Changes made to implement the new place 
of supply rule for telecommunication, 
broadcasting, and electronic services as a 
result of Directive 2006/112/EC, which will 
come into force on 1 January 2015. 
2. Various modifications required as a result 
of recent decisions in the Court of Justice of 
the European Union, including: 
• Application of the general VAT rate (21%), 
rather than the reduced VAT rate (10%), 
on medical and health equipment and 
other medical devices meant for hospital 
use (Case C-360/11). 
• Modification of the Special Regime 
applicable to Travel Agencies 
(Case C-189/11). 
• Modifications to the determination of 
the taxable base for payments in kind 
(Case C-549/11). 
• Abolition of the exemption for 
intervention services provided by public 
notaries in exempt financial transactions. 
• Other miscellaneous modifications. 
3. Various other measures, including: 
• Antifraud measures. 
• Modifications intended to introduce 
technical improvements. 
• Simplification measures within the 
scope of the VAT Directive that are 
meant to clarify and eliminate certain 
requirements. 
The final amending law will be published in the 
State Official Journal in the following months 
with these modifications expected to come 
into force at the end of the year. 
CARLOS BAUTISTA 
ROSARIO ESTELLA 
Spain – Madrid 
carlos.bautista@bdo.es 
rosario.estella@bdo.es
INDIRECT TAX NEWS 3 5 
UGANDA 
THE LEGALITY OF THE IMPOSITION OF DOMESTIC VAT ON IMPORTS OF GOODS INTO UGANDA CHALLENGED 
Like most developing countries, Uganda 
struggles with the problem of how to 
collect tax from one of the biggest 
sectors of the economy: the so-called 
“informal sector”. The legislators and the 
Uganda Revenue Authority (URA) have made 
several attempts to bring Uganda’s informal 
traders within the tax net in a manner that 
is administratively efficient. One such effort 
is the URA’s imposition and collection of 
“domestic VAT” on imports of goods. 
Though the imposition and collection of 
domestic VAT has long been considered 
controversial, it was not legally challenged 
until the class action case of Kiki Rwaheru 
and 13,945 others vs. URA (Civil Suit No. 117 
of 2013). In that case the plaintiffs sought a 
declaration that there is no legal basis for the 
URA to charge domestic VAT on imported 
goods. On 10 January 2014, the Commercial 
Division of the High Court of Uganda delivered 
is partial judgement covering the points of 
law raised in the case. The court will deliver 
its judgment separately on the merits of the 
facts of the case as proven by the plaintiffs, 
particularly for the purposes of awarding costs. 
Background 
Article 152 (1) of Uganda’s Constitution 
of 1995 prohibits the imposition of tax unless 
authorised by an Act of Parliament and there 
is no specific Act of Parliament authorising 
the imposition of domestic VAT on non VAT 
registered importers. As a result, the general 
public and tax community were surprised 
when the URA included a note in its VAT 
guidelines that stated that “Domestic VAT for 
Non VAT registered importers” had come into 
effect on 1 March 2002. In the guidelines the 
URA defined domestic VAT as VAT charged 
on goods whose value is UGX 4 million or 
more. According to the guidelines, importers 
who meet the following are required to pay 
domestic VAT: 
• The importer is not VAT registered. 
• The Cost, Insurance, Freight (CIF) value (as 
determined by Customs) of the goods is 
UGX 4 million or more. 
• The goods are subject to the standard VAT 
rate of 18%. 
• The goods are not personal effects or motor 
vehicles. 
The guidelines further provide that domestic 
VAT is payable at the customs entry point 
together with “other customs taxes” and the 
value for domestic tax purposes is computed 
by applying a 15% mark-up on the value on 
which VAT at Customs is computed, which 
is the sum total of CIF plus import duty and 
excise duty (the so-called Customs VAT value). 
The mark-up is the expected value added 
between the stage of importation and sale. 
Based on the URA’s guidelines, the total 
combined VAT suffered by the importers 
is 33%, which is neither provided for by 
the Value Added Tax Act (Cap 349) nor 
the East African Community Customs 
Management Act, 2004. 
In the Kiki Rwaheru case, the URA explained 
its justification for imposition of domestic 
VAT on imports of goods. According to the 
URA, given the fact that many of taxpayers 
that fall into the informal sector intend to 
circumvent compulsory VAT registration, 
since they do not keep proper records, have 
no fixed places of abode, have multiple 
registrations, or are simply not registered 
for VAT at all, the URA faces administrative 
challenges in ascertaining output VAT. As a 
result, the URA feels it is important to collect 
input VAT (18% VAT at importation) and 
output VAT (domestic VAT at 15%) at the 
point of importation. Furthermore, the URA 
claims that it has authority to do so under 
Section 32 (1) (c) of Cap 349, which empowers 
the URA Commissioner General to make an 
assessment of the amount of tax payable by a 
person where the Commissioner General has 
reasonable grounds to believe that a person 
will become liable to pay tax but is unlikely to 
pay the amount due. 
The URA further explained that the domestic 
VAT did not amount to a different tax with 
a different rate because the calculation was 
based on an estimated mark-up (15%) that 
was meant to represent the expected value 
added on imports between the stage of 
importation and sale in the domestic market, 
taking into account costs incurred as well as 
the profit margin. The URA also noted that 
aggrieved taxpayers had a legal right to file 
a VAT return and could seek a refund for the 
overpaid tax under Section 42 (3) of Cap 349. 
As the plaintiffs’ counsel in the case pointed 
out, by imposing domestic VAT on imports, 
the URA made several assumptions that 
contravened the provisions of Cap 349. First, 
the URA assumed that all imports of goods 
worth over UGX 4,000,000 are for sale in 
the domestic market at a profit and that from 
such a sale, output tax would always exceed 
input tax and, as a result, an importer is always 
in a VAT payable position rather than a VAT 
refundable position. The plaintiffs argued that 
by assuming that all importers of goods worth 
over UGX 4,000,000 are eligible for VAT 
registration, the URA was effectively rendering 
the annual VAT registration threshold 
of UGX 50,000,000 set out in Cap 349 
meaningless. 
And finally, the plaintiffs argued that to require 
unregistered persons to pay VAT without 
establishing whether they are taxable persons 
under the Act is contrary to the provisions of 
Cap 349. 
In concluding that imposition of domestic 
VAT is not illegal per se, the judge pointed 
out that it is was irregular for the URA to 
assess taxes on taxable supplies before the 
supply takes place. The judge added that 
the URA’s conclusion that all importers are 
unlikely to pay VAT on future taxable supplies 
of goods should be determined on a case-by- 
case basis, rather than on a blanket basis 
for administrative convenience. The judge 
concluded that it was unnecessary for the 
URA to resort to relying on estimated VAT 
assessments on speculative future supplies 
and, instead, the URA should use the various 
penal provisions specified by Cap 349, such as 
penalties for failure to apply for registration, 
failure to lodge returns, and failure to maintain 
proper records. 
The judge’s conclusion in this case has 
wide-ranging implications for the URA and 
taxpayers alike. Subject to factual evidence 
and, of course, verification by a URA audit, 
some taxpayers may seek refunds of overpaid 
VAT in accordance with the provisions 
of Cap 349. Given the URA’s practice of 
instigating wide-ranging audits into taxpayer’s 
affairs to verify refunds claimed, the URA may 
be overwhelmed by the large number of pre-refund 
verification audits and possible legal 
challenges that may result. Importers who 
have erroneously paid import VAT face the 
dilemma of deciding whether to pursue the 
VAT refund or to forfeit it in order to avoid the 
intrusive URA audits. 
RITA ZABALI 
Uganda – Kampala 
rita.zabali@bdo-ea.com
6 INDIRECT TAX NEWS 3 
This publication has been carefully prepared, but it has been written 
in general terms and should be seen as broad guidance only. The 
publication cannot be relied upon to cover specific situations and you 
should not act, or refrain from acting, upon the information contained 
herein without obtaining specific professional advice. Please contact 
the appropriate BDO Member Firm to discuss these matters in the 
context of your particular circumstances. Neither the BDO network, 
nor the BDO Member Firms or their partners, employees or agents 
accept or assume any liability or duty of care for any loss arising from 
any action taken or not taken by anyone in reliance on the information 
in this publication or for any decision based on it. 
BDO is an international network of public accounting firms, 
the BDO Member Firms, which perform professional services 
under the name of BDO. Each BDO Member Firm is a member of 
BDO International Limited, a UK company limited by guarantee 
that is the governing entity of the international BDO network. 
Service provision within the BDO network is coordinated by Brussels 
Worldwide Services BVBA, a limited liability company incorporated in 
Belgium with its statutory seat in Brussels. 
Each of BDO International Limited, Brussels Worldwide Services BVBA 
and the member firms of the BDO network is a separate legal entity 
and has no liability for another such entity’s acts or omissions. 
Nothing in the arrangements or rules of the BDO network shall 
constitute or imply an agency relationship or a partnership between 
BDO International Limited, Brussels Worldwide Services BVBA and/ 
or the member firms of the BDO network. 
BDO is the brand name for the BDO network and for each of the 
BDO Member Firms. 
© Brussels Worldwide Services BVBA, September 2014. 1409-02 
CURRENCY COMPARISON TABLE 
The table below shows comparative exchange rates against the euro and the US dollar for 
the currencies mentioned in this issue, as at 17 September 2014. 
Currency unit 
Value in euros 
(EUR) 
Value in US dollars 
(USD) 
Romanian New Lei (RON) 0.22636 0.29310 
Uganda Shilling 0.00029 0.00038 
CONTACT PERSONS 
The BDO VAT Centre of Excellence consists of the following persons: 
Ivor Feerick (Chair) Ireland Dublin ifeerick@bdo.ie 
Andrea Haslinger Austria Vienna andrea.haslinger@bdo.at 
Erwin Boumans Belgium Brussels erwin.boumans@bdo.be 
Annette Pogodda-Grünwald Germany Berlin VAT@bdo.de 
Deirdre Padian Ireland Dublin dpadian@bdo.ie 
Erwan Loquet Luxembourg Luxembourg erwan.loquet@bdo.lu 
Rob Geurtse Netherlands Rotterdam rob.geurtse@bdo.nl 
Claudio Giger Switzerland Zurich claudio.giger@bdo.ch 
Tom Kivlehan United Kingdom Reading tom.kivlehan@bdo.co.uk

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Indirect Tax News_issue 3 September 2014

  • 1. CONTENTS ▶▶BELGIUM Warehousing services: Belgium brings its interpretation in line with the EU implementing regulation 1 ▶▶EDITOR’S LETTER 2 ▶▶ECUADOR Value Added Tax (VAT) on import of services 2 ▶▶IRELAND Adjustment of tax deductible in relation to unpaid consideration 3 ▶▶ISRAEL Israeli and U.S. Customs authorities sign AEO mutual recognition agreement 3 ▶▶LATVIA Recommendations for the assessment of counterparty and transaction risks 3 ▶▶ROMANIA European Court of Justice ruling on Romanian authorities’ treatment of financial leases on termination of lease 4 ▶▶SPAIN Bill amending Spain’s VAT law 4 ▶▶UGANDA The legality of the imposition of domestic VAT on imports of goods into Uganda challenged 5 ECUADOR VAT on import of services READ MORE 2 ISRAEL Israeli and U.S. customs authorities sign AEO mutual recognition agreement READ MORE 3 SEPTEMBER 2014 ISSUE 3 WWW.BDOINTERNATIONAL.COM INDIRECT TAX NEWS BELGIUM WAREHOUSING SERVICES: BELGIUM BRINGS ITS INTERPRETATION IN LINE WITH THE EU IMPLEMENTING REGULATION With effect from 1 June 2014, the Belgian tax authorities have changed the place of supply rules, and hence the liability to Belgian VAT, for the provision of warehousing facilities. When the EU’s place of supply rules were rewritten in 2010, the Belgian VAT authorities initially considered warehousing services to be services connected with immovable property, as referred to in article 47 of Directive 2006/112/EC. However, as this point of view was not in line with some of the other EU Member States, it was temporarily allowed to apply the general B2B place of supply rules. From June 2014, this has changed. Belgium’s new rules now specify which warehousing services are connected with immovable property and which are not. This is believed to be in response to the European Court judgment in the C-155/12 RR Donnelley case last year, and in anticipation of Council Implementing Regulation no. 1042/2013, which becomes binding in all EU Member States in 2017. The new rules outline the VAT treatment of three situations: Exclusive use Where warehousing facilities are provided for the “Exclusive use” of the foreign trader, this is now considered a supply of immovable property as per article 47 of Directive 2006/112/EC. This implies that Belgian VAT is, in principle, due (at the standard rate of 21%) on such services provided in a warehouse located in Belgium, regardless of where the service provider and/or the recipient are established. Article 31a, 2(h) of the Implementing Regulation states that “Services connected with immovable property, as referred to in Article 47 of Directive 2006/112/EC, shall include only those services that have a sufficiently direct connection with that property [...] including the storage of goods for which a specific part of the property is assigned for the exclusive use of the customer.” Facilities are deemed to be for “Exclusive use” if all of the following conditions are met: • The exclusive use must be assigned to the service recipient for the entire period of the agreement; • The service recipient is entitled to freely access its goods in the warehouse, irrespective of the fact that the warehouse owner provides some kind of security; • The agreement must explicitly determine the location of the warehouse or the area within the warehouse where the goods will be stored; • The goods must be identifiable; • The service provider cannot change the actual place of storage of the goods within the warehouse without consent of the owner of the goods; • The service recipient must be able to exclude any other person from the use of the locations attributed to the recipient, and use this at the recipient’s discretion; the owner of the warehouse is not entitled to render any additional services regarding to the stored goods. ROMANIA ECJ ruling on Romanian authorities’ treatment of financial leases on termination of lease READ MORE 4
  • 2. 2 INDIRECT TAX NEWS 3 EDITOR’S LETTER Dear Readers, Greetings from Barcelona where I’m currently transiting en route home to Dublin from Madrid where I hosted BDO’s International VAT & Customs conference for 2014. This year’s conference was attended by 86 delegates from 34 Countries including the US, Canada, South Africa, India, the Dominican Republic, Israel and European countries from both within and outside the European Union. This event, attended by Partners and Senior Management who are all full time Indirect Tax experts, was our largest Conference ever, surpassing last year’s attendance in Dublin by over 33%. It was also the first time that we have had a Customs & International Trade focused forum running in tandem with our mainstream VAT focused event, which enabled all delegates to get together on the first morning and last afternoon of the event. I am very proud of the progress that I and my colleagues at the BDO International VAT Centre of Excellence have made (assisted, of courses, by the leaders of our APAC and Customs sub-groups) over the three years since I initially became Chair. Hopefully it is a source of comfort to you knowing that BDO continues to improve its capacity and that we continue to ensure we have the highest standards to meet the ever increasing demands for both domestic and international guidance and leadership on indirect tax related issues. I hope you will find this edition of ITN a useful source of information and many thanks, as always, to Sarah Halsted our editor, our contributors from around the globe, and our colleagues at the BDO International Office who provide background assistance to us. Kind regards from Dublin. IVOR FEERICK Chair – BDO International VAT Centre of Excellence Committee Ireland – Dublin ifeerick@bdo.ie Non-exclusive use Where the foreign trader does not have exclusive access because other traders may rent the facility too, then the general B2B and B2C rules apply. In general this will be the case if one or more of the previously mentioned criteria are not met, for example if there is no specific warehouse (or part of a warehouse) designated for the goods to be stored at, or if the owner does not have access to the stored goods. Additional warehousing services If warehousing services are rendered along with other services related to the storage of goods, this transaction no longer qualifies as the mere letting of storage space. Under agreements that do not grant an exclusive use and/or the warehouse owner renders a set of services (in order to maintain or improve the quality of the goods) of which the warehouse service is only a part, the link with the warehousing services is less direct. In this case, the general B2B or B2C place of supply rules apply. KAATJE BONDEWEL Belgium – Brussels kaatje.bondewel@bdo.be ECUADOR VALUE ADDED TAX (VAT) ON IMPORT OF SERVICES Value Added Tax (VAT) is levied in Ecuador on the transfer of ownership and importation of goods and services at all stages of manufacture, as well as on copyrights, industrial property, and related rights. In the case of services imported into Ecuador, the tax law specifies that they are subject to VAT at 12%. VAT paid on imported services can be deducted from VAT the importer generates on its sales. In other words, the taxpayer in Ecuador can reduce the VAT it must pay to the tax authorities by the amount of VAT it pays on imported services. In order to qualify for this deduction, the services must meet the following requirements: • The service provider must be domiciled abroad and must provide a proper invoice that shows, in detail, the service provided, the price charged for the service, and identification of the buyer (the taxpayer in Ecuador). • The taxpayer in Ecuador must issue a document authorised by the tax authorities called “Liquidación de Compras de bienes y prestación de servicios”. This document must show the VAT rate of 12% separate from the total cost of the imported services. VAT generated on the importation of services is subject to 100% withholding and must be paid to the Ecuadoran tax authorities by the importer of the services in the month following the registered date of the invoice in the accounting books of the taxpayer. VERONICA PEÑA Ecuador – Quito vpena@advice.com.ec
  • 3. INDIRECT TAX NEWS 3 3 IRELAND ADJUSTMENT OF TAX DEDUCTIBLE IN RELATION TO UNPAID CONSIDERATION ISRAEL ISRAELI AND U.S. CUSTOMS AUTHORITIES SIGN AEO MUTUAL RECOGNITION AGREEMENT LATVIA RECOMMENDATIONS FOR THE ASSESSMENT OF COUNTERPARTY AND TRANSACTION RISKS Introduction The Finance (No. 2) Act 2013 introduced Section 62A to the VAT Consolidation Act 2010. This new Section provides for adjustments to be made in respect of tax deductible in relation to unpaid consideration. In simple terms, this means that where a taxable person has claimed a VAT deduction in a taxable period (referred to as the “initial period”) on a valid VAT invoice received from a supplier but the taxable person has not paid the supplier for the related goods or services within six months, that person must repay to Revenue the amount of input credit originally claimed. This provision was introduced with effect from 1 January 2014. As a result, the consideration in respect of invoices on which VAT was reclaimed in the January/ February 2014 VAT return must be paid no later than 31 August 2014, the last day of the sixth month following the initial period. Consequently, the July/August 2014 VAT return will be the first return that an adjustment in respect of unpaid consideration may arise. Similarly, an adjustment must be made where only part payment is made in satisfaction of the debt. In such cases an adjustment is required to be made in respect of the amount of the invoice that remains unpaid. Where a taxpayer has made a full or partial adjustment but subsequently makes a payment to the supplier, the taxpayer can claim the input credit in its VAT return for the period in which the payment is made. Grounds for not making an adjustment The Revenue Commissioners accept that there may be instances where an adjustment is not required and Revenue has issued some guidance in this regard. The guidelines relate to situations where there are genuine commercial reasons why the taxpayer has made no payment or only partial payment to the supplier. JIMMY RYNHART Ireland – Dublin jrynhart@bdo.ie In June 2014 a mutual recognition agreement was signed by the Israeli Customs authority and the U.S.’s Customs and Border Protection. The agreement acknowledges each other’s approvals process for “Authorised Economic Operator” programs for the purpose of customs mutual simplifications and facilitation (the US program is known as “C-TPAT”, which stands for Customs Trade Partnership against Terrorism). Mutual recognition helps facilitate trade between the two countries because it reduces the need for security and customs inspections of authorised exporters from one country by the customs authority of the other country. An authorised economic operator (or “authorised operator”) is a trader that has been examined by the customs authorities of one of the two countries and has been found to satisfy certain requirements and criteria, such as security, customs compliance, compliance with tax and trade rules and regulations, financial strength, appropriate computerised systems, documentary controls, inventory controls, a proper plan for recovery from catastrophic incident, and so on. Authorised operators will enjoy simplified process regarding their international trading, including: a lower level of customs checking and procedural requirements that will save them time and costs, including, for example, the possibility of having documents examined before the arrival of the Imported goods, and so on. The Authorised Economic Operator program of the Israeli Tax Authority is based on the SAFE Framework of Standards of the World Customs Organisation. As part of this program, unified standards for the security, compliance, and financial viability of the global supply chain were introduced. The program is based on voluntary participation of companies (including importers, exporters, intermediaries, carriers, terminal operators, distributors and so on) that are willing to adopt the SAFE framework for trade facilitation and global supply chain security. As of today, Israel has signed mutual recognition agreements with the American and Taiwan authorities and it is in the process of negotiating such an agreement with South Korea and other countries. AYELET YITZHAKI Israel – Tel Aviv ayelety@bdo.co.il In daily operations, companies are exposed to the risk of being involved in fraudulent transactions. Companies that are involved in such transactions can lose the right to claim deductions in Latvia for input VAT. To minimise the chances of being involved in such transactions, taxpayers should conduct reliability assessments of counterparties they deal with. There are two requirements under the Latvian VAT Act that taxpayers must comply with to recover input VAT: 1. The taxpayer must check to see whether the counterparty is registered in the Latvian VAT register; and 2. If the counterparty is from another Member State, the taxpayer must check to see if the counterparty has a valid VAT number. The Latvian State Revenue Service (SRS) recommends that taxpayers get evidence on counterparties’ reliability themselves. Unfortunately, it is not always possible for taxpayers to obtain all the information about a counterparty (for example, whether a business unit is registered with SRS, whether it uses the assets in its possession for business activities, and so on). As a result, taxpayers are exposed to a certain amount of risk. To help taxpayers protect their right to recover input VAT, the Latvian SRS recently issued recommendations regarding assessment of a counterparty and the risk of a transaction. The recommendations are based on the guidance developed by the United Kingdom. The recommendations outline the steps taxpayers should take to assess reliability of a counterparty. For example, the SRS recommends that taxpayers look for publicly available information on counterparties – things like registration data, licenses and permits issued to the counterparty, information about the counterparty’s financial position (such as liabilities, insolvency proceedings, and so on), and the operational results of the counterparty. It is worth emphasising, however, that the recommendations are for information purposes only and are not binding on taxpayers. INITA SKRODERE GITA AVOTINA Latvia – Riga inita.skrodere@bdotax.lv gita.avotina@bdotax.lv
  • 4. 4 INDIRECT TAX NEWS 3 ROMANIA EUROPEAN COURT OF JUSTICE RULING ON ROMANIAN AUTHORITIES’ TREATMENT OF FINANCIAL LEASES ON TERMINATION OF LEASE The European Court of Justice’s opinion was sought in the Romanian case of BCR Leasing IFN SA vs. National Agency for Fiscal Administration (ANAF)-DGAMC & DGSC with the payment of value added tax on goods leased under a financial leasing contract but deemed missing after not being returned to the leasing company. BCR Leasing (BCR) is a limited company whose main activity is financial leasing. It acquires cars from various suppliers and fully deducts the input VAT paid on these purchases. After acquiring the cars, the company enters into financial leasing contracts with natural and legal persons who then use the vehicles for the term of the contract. BCR remains the owner of the cars. As a result of late or non-payment under the leases, BCR terminated some of the contracts it had with defaulting lessees. Since BCR did not receive payments in respect of the terminated contracts, BCR stopped issuing invoices relating to those contracts and it stopped collecting the corresponding VAT. During an audit carried out in 2011, the tax authorities found irregularities relating to the manner in which BCR indicated, recorded, and declared VAT for the period from 1 September 2008 through 31 December 2010. By notice of 30 August 2011 and a tax audit report of the same date, the tax authorities imposed an additional payment of RON 19,266,551 on BCR in respect of VAT, as well as a penalty of RON 9,502,774 for delayed payment. The tax authorities took the position that for the entire term of a financial lease the lease must be treated as a supply of services and, depending on whether the lessee exercises an option to purchase the vehicle, there may be a supply of goods on expiry of the contract. According to the tax authorities, if the goods are vehicles that are returned to BSR at the end of the financial lease, BSR is required to apply the provisions of the Romanian Fiscal Code on self-supplies and must collection VAT and must issue invoices to itself in respect of those supplies. BSR argued that the national legislation the tax authorities relied on is not compatible with the system introduced by the VAT Directive. As a result, BCR filed an action for the annulment of the tax notice. The Bucharest Court of appeal recently heard the case. Because of the possible conflict between the Romanian tax authorities’ interpretation and the VAT Directive, the ECJ was asked to determine: • Whether a leasing company could be considered to supply goods for consideration within the meaning of article 16 of Directive 2016/112/EC in which the lease terminated as a result of the lessee’s breach of the terms of the lease and the lessor has followed the statutory procedures for recovery but did not recover anything from the lessee. Or, • Whether there might there be a supply of goods for consideration within the meaning of Article 18 of Directive 2006/112/EC. The ECJ ruled (Judgment C-438/13) that Articles 16 and 18 of Directive 2006/112/EC must be interpreted as meaning that there has not been a supply of goods for consideration for the purposes of the Directive if a leasing company cannot recover from the lessee following termination as a result of the lessee’s breach and therefore BCR should not be required to collect VAT for unrecovered goods from the lessees. DAN BARASCU HORIA MATEI Romania – Bucharest dan.barascu@bdo.ro horia.matei@bdo.ro SPAIN BILL AMENDING SPAIN’S VAT LAW On 6 August 2014 a proposed bill amending various provisions of Spain’s VAT law was published in the Houses Official Journal. The provisions of the bill can be categorised into three groups: 1. Changes made to implement the new place of supply rule for telecommunication, broadcasting, and electronic services as a result of Directive 2006/112/EC, which will come into force on 1 January 2015. 2. Various modifications required as a result of recent decisions in the Court of Justice of the European Union, including: • Application of the general VAT rate (21%), rather than the reduced VAT rate (10%), on medical and health equipment and other medical devices meant for hospital use (Case C-360/11). • Modification of the Special Regime applicable to Travel Agencies (Case C-189/11). • Modifications to the determination of the taxable base for payments in kind (Case C-549/11). • Abolition of the exemption for intervention services provided by public notaries in exempt financial transactions. • Other miscellaneous modifications. 3. Various other measures, including: • Antifraud measures. • Modifications intended to introduce technical improvements. • Simplification measures within the scope of the VAT Directive that are meant to clarify and eliminate certain requirements. The final amending law will be published in the State Official Journal in the following months with these modifications expected to come into force at the end of the year. CARLOS BAUTISTA ROSARIO ESTELLA Spain – Madrid carlos.bautista@bdo.es rosario.estella@bdo.es
  • 5. INDIRECT TAX NEWS 3 5 UGANDA THE LEGALITY OF THE IMPOSITION OF DOMESTIC VAT ON IMPORTS OF GOODS INTO UGANDA CHALLENGED Like most developing countries, Uganda struggles with the problem of how to collect tax from one of the biggest sectors of the economy: the so-called “informal sector”. The legislators and the Uganda Revenue Authority (URA) have made several attempts to bring Uganda’s informal traders within the tax net in a manner that is administratively efficient. One such effort is the URA’s imposition and collection of “domestic VAT” on imports of goods. Though the imposition and collection of domestic VAT has long been considered controversial, it was not legally challenged until the class action case of Kiki Rwaheru and 13,945 others vs. URA (Civil Suit No. 117 of 2013). In that case the plaintiffs sought a declaration that there is no legal basis for the URA to charge domestic VAT on imported goods. On 10 January 2014, the Commercial Division of the High Court of Uganda delivered is partial judgement covering the points of law raised in the case. The court will deliver its judgment separately on the merits of the facts of the case as proven by the plaintiffs, particularly for the purposes of awarding costs. Background Article 152 (1) of Uganda’s Constitution of 1995 prohibits the imposition of tax unless authorised by an Act of Parliament and there is no specific Act of Parliament authorising the imposition of domestic VAT on non VAT registered importers. As a result, the general public and tax community were surprised when the URA included a note in its VAT guidelines that stated that “Domestic VAT for Non VAT registered importers” had come into effect on 1 March 2002. In the guidelines the URA defined domestic VAT as VAT charged on goods whose value is UGX 4 million or more. According to the guidelines, importers who meet the following are required to pay domestic VAT: • The importer is not VAT registered. • The Cost, Insurance, Freight (CIF) value (as determined by Customs) of the goods is UGX 4 million or more. • The goods are subject to the standard VAT rate of 18%. • The goods are not personal effects or motor vehicles. The guidelines further provide that domestic VAT is payable at the customs entry point together with “other customs taxes” and the value for domestic tax purposes is computed by applying a 15% mark-up on the value on which VAT at Customs is computed, which is the sum total of CIF plus import duty and excise duty (the so-called Customs VAT value). The mark-up is the expected value added between the stage of importation and sale. Based on the URA’s guidelines, the total combined VAT suffered by the importers is 33%, which is neither provided for by the Value Added Tax Act (Cap 349) nor the East African Community Customs Management Act, 2004. In the Kiki Rwaheru case, the URA explained its justification for imposition of domestic VAT on imports of goods. According to the URA, given the fact that many of taxpayers that fall into the informal sector intend to circumvent compulsory VAT registration, since they do not keep proper records, have no fixed places of abode, have multiple registrations, or are simply not registered for VAT at all, the URA faces administrative challenges in ascertaining output VAT. As a result, the URA feels it is important to collect input VAT (18% VAT at importation) and output VAT (domestic VAT at 15%) at the point of importation. Furthermore, the URA claims that it has authority to do so under Section 32 (1) (c) of Cap 349, which empowers the URA Commissioner General to make an assessment of the amount of tax payable by a person where the Commissioner General has reasonable grounds to believe that a person will become liable to pay tax but is unlikely to pay the amount due. The URA further explained that the domestic VAT did not amount to a different tax with a different rate because the calculation was based on an estimated mark-up (15%) that was meant to represent the expected value added on imports between the stage of importation and sale in the domestic market, taking into account costs incurred as well as the profit margin. The URA also noted that aggrieved taxpayers had a legal right to file a VAT return and could seek a refund for the overpaid tax under Section 42 (3) of Cap 349. As the plaintiffs’ counsel in the case pointed out, by imposing domestic VAT on imports, the URA made several assumptions that contravened the provisions of Cap 349. First, the URA assumed that all imports of goods worth over UGX 4,000,000 are for sale in the domestic market at a profit and that from such a sale, output tax would always exceed input tax and, as a result, an importer is always in a VAT payable position rather than a VAT refundable position. The plaintiffs argued that by assuming that all importers of goods worth over UGX 4,000,000 are eligible for VAT registration, the URA was effectively rendering the annual VAT registration threshold of UGX 50,000,000 set out in Cap 349 meaningless. And finally, the plaintiffs argued that to require unregistered persons to pay VAT without establishing whether they are taxable persons under the Act is contrary to the provisions of Cap 349. In concluding that imposition of domestic VAT is not illegal per se, the judge pointed out that it is was irregular for the URA to assess taxes on taxable supplies before the supply takes place. The judge added that the URA’s conclusion that all importers are unlikely to pay VAT on future taxable supplies of goods should be determined on a case-by- case basis, rather than on a blanket basis for administrative convenience. The judge concluded that it was unnecessary for the URA to resort to relying on estimated VAT assessments on speculative future supplies and, instead, the URA should use the various penal provisions specified by Cap 349, such as penalties for failure to apply for registration, failure to lodge returns, and failure to maintain proper records. The judge’s conclusion in this case has wide-ranging implications for the URA and taxpayers alike. Subject to factual evidence and, of course, verification by a URA audit, some taxpayers may seek refunds of overpaid VAT in accordance with the provisions of Cap 349. Given the URA’s practice of instigating wide-ranging audits into taxpayer’s affairs to verify refunds claimed, the URA may be overwhelmed by the large number of pre-refund verification audits and possible legal challenges that may result. Importers who have erroneously paid import VAT face the dilemma of deciding whether to pursue the VAT refund or to forfeit it in order to avoid the intrusive URA audits. RITA ZABALI Uganda – Kampala rita.zabali@bdo-ea.com
  • 6. 6 INDIRECT TAX NEWS 3 This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained herein without obtaining specific professional advice. Please contact the appropriate BDO Member Firm to discuss these matters in the context of your particular circumstances. Neither the BDO network, nor the BDO Member Firms or their partners, employees or agents accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it. BDO is an international network of public accounting firms, the BDO Member Firms, which perform professional services under the name of BDO. Each BDO Member Firm is a member of BDO International Limited, a UK company limited by guarantee that is the governing entity of the international BDO network. Service provision within the BDO network is coordinated by Brussels Worldwide Services BVBA, a limited liability company incorporated in Belgium with its statutory seat in Brussels. Each of BDO International Limited, Brussels Worldwide Services BVBA and the member firms of the BDO network is a separate legal entity and has no liability for another such entity’s acts or omissions. Nothing in the arrangements or rules of the BDO network shall constitute or imply an agency relationship or a partnership between BDO International Limited, Brussels Worldwide Services BVBA and/ or the member firms of the BDO network. BDO is the brand name for the BDO network and for each of the BDO Member Firms. © Brussels Worldwide Services BVBA, September 2014. 1409-02 CURRENCY COMPARISON TABLE The table below shows comparative exchange rates against the euro and the US dollar for the currencies mentioned in this issue, as at 17 September 2014. Currency unit Value in euros (EUR) Value in US dollars (USD) Romanian New Lei (RON) 0.22636 0.29310 Uganda Shilling 0.00029 0.00038 CONTACT PERSONS The BDO VAT Centre of Excellence consists of the following persons: Ivor Feerick (Chair) Ireland Dublin ifeerick@bdo.ie Andrea Haslinger Austria Vienna andrea.haslinger@bdo.at Erwin Boumans Belgium Brussels erwin.boumans@bdo.be Annette Pogodda-Grünwald Germany Berlin VAT@bdo.de Deirdre Padian Ireland Dublin dpadian@bdo.ie Erwan Loquet Luxembourg Luxembourg erwan.loquet@bdo.lu Rob Geurtse Netherlands Rotterdam rob.geurtse@bdo.nl Claudio Giger Switzerland Zurich claudio.giger@bdo.ch Tom Kivlehan United Kingdom Reading tom.kivlehan@bdo.co.uk