Case alert Isle of Wight - Court of Appeal
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This document summarizes a court case regarding whether local authorities providing off-street car parking should be subject to VAT. The Court of Appeal dismissed the appeal from several Councils and found that exempting local authorities from VAT on car parking activities would distort competition with commercial car parking providers that do pay VAT. The Court agreed with earlier rulings from the First-tier Tax Tribunal and Upper Tribunal that if local authorities did not charge VAT, they could lower prices and impact the profits and prices of commercial competitors operating in the same market.
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Case alert VW Financial Services (UK) Ltd v HMRC
This document summarizes a court case between VW Financial Services (VWFS) and Her Majesty's Revenue and Customs (HMRC). The Court of Appeal ruled in favor of VWFS on two grounds. First, it found that VWFS was entitled to reclaim value-added tax (VAT) incurred on general overheads, as these overheads had a direct link to both the taxable sale of cars and exempt financing activities. Second, it agreed with VWFS's apportionment of claiming 50% of residual input VAT based on there being two supplies (car and financing) per transaction. The ruling was a major victory for VWFS and loss for HMRC.
Case Alert - Wiltonpark Ltd & Ors Court of Appeal
This document provides information about Grant Thornton, an accounting organization. It states that Grant Thornton is a member firm of Grant Thornton International Ltd, but that GTIL and its member firms are separate legal entities that do not obligate one another. It also notes that this publication is intended as a guide and Grant Thornton cannot be liable for any losses resulting from relying on the information herein.
Indirect Tax Update 20/2015
The Upper Tribunal issued two interesting judgments this week:
1) In the case of Secrets (Promotions) Ltd, the Tribunal ruled that exchanging a virtual currency ("Secrets" money) for sterling at a 20% commission was a taxable facilitation service, not an exempt financial service.
2) In Capernwray Missionary Fellowship, the Tribunal refused to refer questions to the European Court of Justice on whether the taxpayer's Bible study activities were "economic activities" subject to VAT.
Additionally, the First-tier Tax Tribunal heard a case on whether golf clubs were "unjustly enriched" by refund claims for VAT paid on green fees, with a decision still pending.
Case Alert: National Roads Authority - CJEU judgment
This document summarizes a case referred to the Court of Justice of the European Union regarding whether tolls charged by the National Roads Authority (NRA) for operating certain roads should be subject to value-added tax (VAT). Generally, activities of public bodies are not subject to VAT, but there is an exception if not charging VAT would significantly distort competition. The Court ruled that the NRA toll roads were not in competition with private toll operators, as customers can only use one road at a time, and private operators could not realistically enter the market. Therefore, the NRA tolls did not need to be subject to VAT in order to prevent competition distortion.
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Case alert - Heating and Plumbing Supplies Ltd
The document summarizes a tax tribunal case regarding a company that incurred professional fees during a management buyout. The tribunal ruled that as the buyout company and target formed a VAT group, they must be treated as a single taxable entity rather than in isolation. As the VAT group only made taxable supplies, it was entitled to reclaim all input VAT on the professional fees, even though the buyout company alone had no economic activity. The tribunal dismissed the tax authority's view that input VAT recovery should be denied if not claimable by the buyout company separately.
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The document summarizes a Supreme Court case ruling regarding whether a company called Airtours was entitled to recover VAT paid on professional services. The Supreme Court ruled by a 3-2 majority that the services were supplied to financial institutions that commissioned the work, not Airtours, even though Airtours paid for them. Therefore, Airtours could not claim the VAT as input tax. The case involved many years of legal proceedings to determine who exactly the services were supplied to for VAT purposes.
UK Case Alert: Airtours loses VAT case at Supreme Court
The issue in this case is whether Airtours was entitled to recover VAT as input tax that it had paid on the supply of professional services. The issue seems quite a simple one but the matter has taken many years to resolve.
The Supreme Court has decided by a majority of 3 to 2 that the professional services were not supplied to Airtours but were supplied to the financial institutions that commissioned the work.
The fact that Airtours paid for the services under the terms of an agreement it had signed with the institutions did not mean that it was entitled to reclaim the VAT charged as input tax.
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This document summarizes a court case between VW Financial Services (VWFS) and Her Majesty's Revenue and Customs (HMRC). The Court of Appeal ruled in favor of VWFS on two grounds. First, it found that VWFS was entitled to reclaim value-added tax (VAT) incurred on general overheads, as these overheads had a direct link to both the taxable sale of cars and exempt financing activities. Second, it agreed with VWFS's apportionment of claiming 50% of residual input VAT based on there being two supplies (car and financing) per transaction. The ruling was a major victory for VWFS and loss for HMRC.
Case Alert - Wiltonpark Ltd & Ors Court of Appeal
This document provides information about Grant Thornton, an accounting organization. It states that Grant Thornton is a member firm of Grant Thornton International Ltd, but that GTIL and its member firms are separate legal entities that do not obligate one another. It also notes that this publication is intended as a guide and Grant Thornton cannot be liable for any losses resulting from relying on the information herein.
Indirect Tax Update 20/2015
The Upper Tribunal issued two interesting judgments this week:
1) In the case of Secrets (Promotions) Ltd, the Tribunal ruled that exchanging a virtual currency ("Secrets" money) for sterling at a 20% commission was a taxable facilitation service, not an exempt financial service.
2) In Capernwray Missionary Fellowship, the Tribunal refused to refer questions to the European Court of Justice on whether the taxpayer's Bible study activities were "economic activities" subject to VAT.
Additionally, the First-tier Tax Tribunal heard a case on whether golf clubs were "unjustly enriched" by refund claims for VAT paid on green fees, with a decision still pending.
Case Alert: National Roads Authority - CJEU judgment
This document summarizes a case referred to the Court of Justice of the European Union regarding whether tolls charged by the National Roads Authority (NRA) for operating certain roads should be subject to value-added tax (VAT). Generally, activities of public bodies are not subject to VAT, but there is an exception if not charging VAT would significantly distort competition. The Court ruled that the NRA toll roads were not in competition with private toll operators, as customers can only use one road at a time, and private operators could not realistically enter the market. Therefore, the NRA tolls did not need to be subject to VAT in order to prevent competition distortion.
Case alert Finmeccanica Global Services SpA - Court of Appeal
This document summarizes a court case regarding an Italian company, Finmeccanica Global Services SpA, that incurred costs in the UK and sought to reclaim VAT from the UK. The court ruled that Finmeccanica had made supplies in the UK by invoicing costs to other group companies for construction and operation of an enclosure at an air show. As making supplies in the country where VAT is claimed is not allowed, Finmeccanica was not entitled to the VAT refund. The court determined the essential service was making the air show event possible at that location and time, not advertising as Finmeccanica had argued.
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The document summarizes a tax tribunal case regarding a company that incurred professional fees during a management buyout. The tribunal ruled that as the buyout company and target formed a VAT group, they must be treated as a single taxable entity rather than in isolation. As the VAT group only made taxable supplies, it was entitled to reclaim all input VAT on the professional fees, even though the buyout company alone had no economic activity. The tribunal dismissed the tax authority's view that input VAT recovery should be denied if not claimable by the buyout company separately.
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The document summarizes a Supreme Court case ruling regarding whether a company called Airtours was entitled to recover VAT paid on professional services. The Supreme Court ruled by a 3-2 majority that the services were supplied to financial institutions that commissioned the work, not Airtours, even though Airtours paid for them. Therefore, Airtours could not claim the VAT as input tax. The case involved many years of legal proceedings to determine who exactly the services were supplied to for VAT purposes.
UK Case Alert: Airtours loses VAT case at Supreme Court
The issue in this case is whether Airtours was entitled to recover VAT as input tax that it had paid on the supply of professional services. The issue seems quite a simple one but the matter has taken many years to resolve.
The Supreme Court has decided by a majority of 3 to 2 that the professional services were not supplied to Airtours but were supplied to the financial institutions that commissioned the work.
The fact that Airtours paid for the services under the terms of an agreement it had signed with the institutions did not mean that it was entitled to reclaim the VAT charged as input tax.
Indirect Tax Update 21/2014
The Court of Appeal ruled that HMRC has the power to offset a previous overclaim of input tax against an overpayment of output tax, even if the normal time limits would bar it. The case involved Birmingham Hippodrome Theatre, which had incorrectly accounted for and paid output tax on exempt box office receipts between 2000-2001. It also claimed input tax on refurbishment works. The Court ruled that HMRC could offset the input tax claimed in error against the theatre's claim for repayment of overpaid output tax, as both errors stemmed from the same original mistake regarding the VAT treatment of box office receipts. This outcome prevents unjust enrichment of the theatre by putting it in the position it would have been in had VAT
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The document summarizes two recent indirect tax cases. In the first case, the Court of Appeal ruled that accountancy services provided to a travel company during financial restructuring were actually provided to creditor banks, not the company, so the company could not reclaim input VAT. In the second case, the First-tier Tribunal ruled against a home builder's claim that it could reclaim VAT on white goods installed in new homes, finding the UK's VAT "blocking" legislation applied. The decisions emphasize considering who services are provided to for VAT purposes and that litigation over large sums, like the £30 million at issue in the second case, will likely continue.
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Indirect Tax Update for week ending 24 January 2014.
Two important Court decisions this week. Firstly, the Court of appeal unanimously rejects Reed Employment Ltd's appeal relating to unjust enrichment. Secondly, the First-tier Tribunal finds that an 'agreement to settle' entered into with a taxpayer was a binding compromise agreement which precluded HMRC from issuing a recovery assessment.
Case alert ifx cof a
This Court of Appeal decisions looks at the definition of a game of chance - and therefore whether the conditions for the Betting & Gaming VAT exemption are met.
Case Alert - Birmingham Hippodrome Theatre Trust
The Court of Appeal unanimously dismissed an appeal from Birmingham Hippodrome Theatre Trust regarding HMRC's right to offset previously claimed input tax against a claim for overpaid output tax. While the theatre had incorrectly accounted for and paid output tax on box office receipts, it had also claimed input tax on refurbishment works. The Court confirmed that under section 81(3A) of the VAT Act, HMRC is entitled to offset the input tax claimed in error to prevent unjust enrichment, effectively putting the Trust back in the position it would have been had VAT been implemented correctly. The Court also found that the offsetting did not infringe EU law principles and the Trust's only remaining appeal option is the Supreme Court.
Case Alert - IFX Investments Ltd
This document summarizes a court case regarding whether income from 'Spot the Ball' competitions is exempt from VAT tax in the UK. It discusses that IFX, which operates Spot the Ball competitions, argued the competitions were exempt as a 'game of chance'. HMRC disagreed, but the First-tier Tax Tribunal sided with IFX. The Upper Tribunal then reversed this decision, but the Court of Appeal has now restored the First-tier Tribunal's original ruling, deeming Spot the Ball a game of chance and its income exempt from VAT. HMRC may seek to appeal the ruling to the UK Supreme Court.
ITU 27/2016
The Advocate General issued an opinion in an Irish case referred to the Court of Justice. The case concerned whether road tolls collected by the Irish National Roads Authority (NRA) should be subject to VAT. The Advocate General concluded that VAT is due, as where tolls can be collected by both public and private bodies, public bodies must be treated as taxable persons to prevent distortions of competition, even if the roads are different. The Court also heard a case on whether the British Film Institute supplies cultural services exempt from VAT. Finally, the Advocate General deemed that greenhouse gas emission allowances should be considered similar rights to intellectual property for place of supply VAT rules.
UK: VAT use and enjoyment on advertising services?
Under normal VAT rules, the place of supply of a business to business (B2B) service is the place where the recipient of the service belongs. In cases where the recipient is outside the European Union, this generally means that no EU VAT is chargeable.
However, 'use and enjoyment' provisions allow national Tax Authorities to adapt the place of supply rules outlined in the Principle VAT Directive where they perceive a threat to the tax yield.
We understand that HM Treasury is considering ways in which these provisions could be enacted in relation to advertising services which could be detrimental to the Betting & Gaming Sector.
ITU 02/2017
This document summarizes two court cases related to VAT (Value Added Tax) in the UK. The first case discusses a CJEU ruling that an Irish public roads authority (NRA) was not in competition with private toll road operators and therefore was not subject to VAT. The second case discusses an Upper Tribunal upholding a previous ruling that motor homes do not qualify as caravans for VAT purposes. The document also briefly summarizes two First-Tier Tribunal cases related to excise duty authorizations.
UK: HMRC implements import anti-fraud campaign
1) HMRC estimates it loses £1.5 billion per year to import VAT fraud such as undervaluation of goods, misclassification of goods, and goods entering the UK but not being exported to another EU country as intended.
2) HMRC is considering shifting liability for this fraud to UK companies that unintentionally facilitate the fraud by providing online trading platforms for the goods.
3) Companies that operate online trading platforms are advised to implement robust due diligence procedures to verify third-party sellers to avoid potential future liability for unpaid import taxes and duties.
ITU 23/2016
The Scottish Court of Session ruled that within a VAT group, only the representative member is entitled to claim VAT refunds, not the individual members. The Upper Tribunal dismissed an appeal regarding apportionment of input VAT between taxable and non-taxable activities. The Court of Justice ruled that "screenplays" should be classified as video producing apparatus for customs duty purposes based on their objective characteristics.
ITU 21/2015
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Case Alert Berkshire Golf Club & others v HMRC
The document summarizes a tax tribunal decision in a case between HMRC and various golf clubs regarding VAT repayment claims. The tribunal ruled that golf clubs should be repaid 90% of VAT claims for "green fees" paid by visitors, rejecting HMRC's argument that full repayment would constitute unjust enrichment. However, the tribunal agreed with HMRC that VAT is due on supplies to corporate customers and tour operators. It also determined expenditure on golf courses could be partially exempt for VAT purposes. Both parties may appeal aspects of the decision to an upper tribunal.
ITU 32/2016
The First-tier Tax Tribunal issued decisions in two cases. In Hotels4U.com v HMRC, the Tribunal followed the precedent from an earlier Supreme Court case and found that Hotels4U.com acted as an agent for hotels, not a principal, so was not subject to the UK Tour Operators' Margin Scheme for VAT. In Water Property Ltd, the Tribunal rejected HMRC's argument that an option to tax should be disapplied due to anti-avoidance rules, as there was no evidence of tax avoidance. The Tribunal also alerted importers that six countries will start using the new EU Registered Exporters scheme from January 2017, which could impact their ability to claim customs duty reductions if their
Case Alert HMRC v VWFS - Supreme Court
This document summarizes a legal case involving Volkswagen Financial Services (VWFS) and Her Majesty's Revenue and Customs (HMRC) regarding the apportionment of value-added tax (VAT) on overhead costs between VWFS's taxable sales of vehicles and exempt sales of vehicle financing. The UK Supreme Court decided to refer the case to the European Court of Justice for a preliminary ruling on whether VWFS is entitled to reclaim a portion of its overhead VAT costs.
Case Alert - The Open University
This document summarizes a court case between HMRC (Her Majesty's Revenue and Customs) and The Open University regarding VAT (value added tax) charged by the BBC on educational programming and broadcasting services provided to The Open University over many years. The Court of Appeal unanimously dismissed HMRC's appeal and found that the BBC, while not a public body, had similar educational objectives and its services to The Open University were closely related to education and should have been VAT exempt. The ruling determined that UK law needs to be amended to properly implement the VAT Directive and recognize bodies with similar educational aims to public bodies.
ITU 31/2016
The Court of Justice ruled that Germany could not deny VAT exemption for the transfer of a vehicle from Germany to Spain by a taxpayer simply because the taxpayer failed to include a VAT number on the invoice, as long as the substantive requirements for exemption were met. The failure to comply with this formal requirement should not prevent exemption from being available, unless tax evasion was suspected. The German law preventing exemption due to missing a VAT number on the invoice violated the purpose of the VAT Directive.
Additionally, the Upper Tribunal affirmed that for VAT groups in the UK, the representative member of the group is entitled to receive any VAT refunds, even if another group member made the supplies and initially overpaid VAT. Individual group members cannot claim refund
Excise Alert: B&M Retail Limited v HMRC
The Upper Tribunal has ruled that HMRC is entitled to assess traders in possession of excise goods for excise duty where there is no evidence that the duty has been paid. When buying excisable products, businesses are advised to ensure that procedures are in place to evidence that a duty point has occurred and excise duty has been paid earlier in the supply chain.
ITU 10/2016
The document summarizes two key developments from the past week:
1) A Court of Justice ruling found that claims handling services provided to an insurer are not exempt from VAT as insurance transactions or related services. UK law will need to change and businesses providing these services should review their VAT position.
2) The UK budget announced new powers for HMRC to make online marketplaces jointly liable for VAT debts of overseas sellers on their platforms. This aims to reduce the estimated £365 million annual VAT loss from non-compliant foreign traders. Online portals will need to strengthen due diligence of sellers.
Vat Alert - reverse charge
Grant Thornton UK LLP is a member firm of Grant Thornton International Ltd, which provides assurance, tax, and advisory services through independent member firms. Grant Thornton UK LLP is a separate legal entity from other member firms. This document provides information about Grant Thornton but does not constitute legal advice and readers should consult professionals for guidance.
Fischvierterl am Naschmarkt - Certificate of Service
Rev.com certified that they translated a document from German to English titled "Fischvierterl am Naschmarkt – Certificate of Service". The translation was performed by experienced translators and accurately reflects the content, meaning, and style of the original document. However, Rev.com does not guarantee the authenticity of the original document or the veracity of its contents. They also do not assume liability for how their customers use the translation. A copy of the certified translation was attached to the certification.
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Indirect Tax Update 21/2014
The Court of Appeal ruled that HMRC has the power to offset a previous overclaim of input tax against an overpayment of output tax, even if the normal time limits would bar it. The case involved Birmingham Hippodrome Theatre, which had incorrectly accounted for and paid output tax on exempt box office receipts between 2000-2001. It also claimed input tax on refurbishment works. The Court ruled that HMRC could offset the input tax claimed in error against the theatre's claim for repayment of overpaid output tax, as both errors stemmed from the same original mistake regarding the VAT treatment of box office receipts. This outcome prevents unjust enrichment of the theatre by putting it in the position it would have been in had VAT
Indirect Tax Update 29/2014
The document summarizes two recent indirect tax cases. In the first case, the Court of Appeal ruled that accountancy services provided to a travel company during financial restructuring were actually provided to creditor banks, not the company, so the company could not reclaim input VAT. In the second case, the First-tier Tribunal ruled against a home builder's claim that it could reclaim VAT on white goods installed in new homes, finding the UK's VAT "blocking" legislation applied. The decisions emphasize considering who services are provided to for VAT purposes and that litigation over large sums, like the £30 million at issue in the second case, will likely continue.
Indirect Tax Update 04/2014
Indirect Tax Update for week ending 24 January 2014.
Two important Court decisions this week. Firstly, the Court of appeal unanimously rejects Reed Employment Ltd's appeal relating to unjust enrichment. Secondly, the First-tier Tribunal finds that an 'agreement to settle' entered into with a taxpayer was a binding compromise agreement which precluded HMRC from issuing a recovery assessment.
Case alert ifx cof a
This Court of Appeal decisions looks at the definition of a game of chance - and therefore whether the conditions for the Betting & Gaming VAT exemption are met.
Case Alert - Birmingham Hippodrome Theatre Trust
The Court of Appeal unanimously dismissed an appeal from Birmingham Hippodrome Theatre Trust regarding HMRC's right to offset previously claimed input tax against a claim for overpaid output tax. While the theatre had incorrectly accounted for and paid output tax on box office receipts, it had also claimed input tax on refurbishment works. The Court confirmed that under section 81(3A) of the VAT Act, HMRC is entitled to offset the input tax claimed in error to prevent unjust enrichment, effectively putting the Trust back in the position it would have been had VAT been implemented correctly. The Court also found that the offsetting did not infringe EU law principles and the Trust's only remaining appeal option is the Supreme Court.
Case Alert - IFX Investments Ltd
This document summarizes a court case regarding whether income from 'Spot the Ball' competitions is exempt from VAT tax in the UK. It discusses that IFX, which operates Spot the Ball competitions, argued the competitions were exempt as a 'game of chance'. HMRC disagreed, but the First-tier Tax Tribunal sided with IFX. The Upper Tribunal then reversed this decision, but the Court of Appeal has now restored the First-tier Tribunal's original ruling, deeming Spot the Ball a game of chance and its income exempt from VAT. HMRC may seek to appeal the ruling to the UK Supreme Court.
ITU 27/2016
The Advocate General issued an opinion in an Irish case referred to the Court of Justice. The case concerned whether road tolls collected by the Irish National Roads Authority (NRA) should be subject to VAT. The Advocate General concluded that VAT is due, as where tolls can be collected by both public and private bodies, public bodies must be treated as taxable persons to prevent distortions of competition, even if the roads are different. The Court also heard a case on whether the British Film Institute supplies cultural services exempt from VAT. Finally, the Advocate General deemed that greenhouse gas emission allowances should be considered similar rights to intellectual property for place of supply VAT rules.
UK: VAT use and enjoyment on advertising services?
Under normal VAT rules, the place of supply of a business to business (B2B) service is the place where the recipient of the service belongs. In cases where the recipient is outside the European Union, this generally means that no EU VAT is chargeable.
However, 'use and enjoyment' provisions allow national Tax Authorities to adapt the place of supply rules outlined in the Principle VAT Directive where they perceive a threat to the tax yield.
We understand that HM Treasury is considering ways in which these provisions could be enacted in relation to advertising services which could be detrimental to the Betting & Gaming Sector.
ITU 02/2017
This document summarizes two court cases related to VAT (Value Added Tax) in the UK. The first case discusses a CJEU ruling that an Irish public roads authority (NRA) was not in competition with private toll road operators and therefore was not subject to VAT. The second case discusses an Upper Tribunal upholding a previous ruling that motor homes do not qualify as caravans for VAT purposes. The document also briefly summarizes two First-Tier Tribunal cases related to excise duty authorizations.
UK: HMRC implements import anti-fraud campaign
1) HMRC estimates it loses £1.5 billion per year to import VAT fraud such as undervaluation of goods, misclassification of goods, and goods entering the UK but not being exported to another EU country as intended.
2) HMRC is considering shifting liability for this fraud to UK companies that unintentionally facilitate the fraud by providing online trading platforms for the goods.
3) Companies that operate online trading platforms are advised to implement robust due diligence procedures to verify third-party sellers to avoid potential future liability for unpaid import taxes and duties.
ITU 23/2016
The Scottish Court of Session ruled that within a VAT group, only the representative member is entitled to claim VAT refunds, not the individual members. The Upper Tribunal dismissed an appeal regarding apportionment of input VAT between taxable and non-taxable activities. The Court of Justice ruled that "screenplays" should be classified as video producing apparatus for customs duty purposes based on their objective characteristics.
ITU 21/2015
The UK Supreme Court issued two VAT judgments in two weeks. In the Rank case, the Supreme Court ruled that Rank's slot machines were 'gaming machines' subject to VAT, agreeing with the lower courts. The Court of Justice of the EU examined the principle of legal certainty in two cases, ruling that retroactive VAT assessments did not violate the principle. The Upper Tribunal ruled that the transfer of a business to a company within a VAT group can qualify as a transfer of a going concern for VAT purposes.
Case Alert Berkshire Golf Club & others v HMRC
The document summarizes a tax tribunal decision in a case between HMRC and various golf clubs regarding VAT repayment claims. The tribunal ruled that golf clubs should be repaid 90% of VAT claims for "green fees" paid by visitors, rejecting HMRC's argument that full repayment would constitute unjust enrichment. However, the tribunal agreed with HMRC that VAT is due on supplies to corporate customers and tour operators. It also determined expenditure on golf courses could be partially exempt for VAT purposes. Both parties may appeal aspects of the decision to an upper tribunal.
ITU 32/2016
The First-tier Tax Tribunal issued decisions in two cases. In Hotels4U.com v HMRC, the Tribunal followed the precedent from an earlier Supreme Court case and found that Hotels4U.com acted as an agent for hotels, not a principal, so was not subject to the UK Tour Operators' Margin Scheme for VAT. In Water Property Ltd, the Tribunal rejected HMRC's argument that an option to tax should be disapplied due to anti-avoidance rules, as there was no evidence of tax avoidance. The Tribunal also alerted importers that six countries will start using the new EU Registered Exporters scheme from January 2017, which could impact their ability to claim customs duty reductions if their
Case Alert HMRC v VWFS - Supreme Court
This document summarizes a legal case involving Volkswagen Financial Services (VWFS) and Her Majesty's Revenue and Customs (HMRC) regarding the apportionment of value-added tax (VAT) on overhead costs between VWFS's taxable sales of vehicles and exempt sales of vehicle financing. The UK Supreme Court decided to refer the case to the European Court of Justice for a preliminary ruling on whether VWFS is entitled to reclaim a portion of its overhead VAT costs.
Case Alert - The Open University
This document summarizes a court case between HMRC (Her Majesty's Revenue and Customs) and The Open University regarding VAT (value added tax) charged by the BBC on educational programming and broadcasting services provided to The Open University over many years. The Court of Appeal unanimously dismissed HMRC's appeal and found that the BBC, while not a public body, had similar educational objectives and its services to The Open University were closely related to education and should have been VAT exempt. The ruling determined that UK law needs to be amended to properly implement the VAT Directive and recognize bodies with similar educational aims to public bodies.
ITU 31/2016
The Court of Justice ruled that Germany could not deny VAT exemption for the transfer of a vehicle from Germany to Spain by a taxpayer simply because the taxpayer failed to include a VAT number on the invoice, as long as the substantive requirements for exemption were met. The failure to comply with this formal requirement should not prevent exemption from being available, unless tax evasion was suspected. The German law preventing exemption due to missing a VAT number on the invoice violated the purpose of the VAT Directive.
Additionally, the Upper Tribunal affirmed that for VAT groups in the UK, the representative member of the group is entitled to receive any VAT refunds, even if another group member made the supplies and initially overpaid VAT. Individual group members cannot claim refund
Excise Alert: B&M Retail Limited v HMRC
The Upper Tribunal has ruled that HMRC is entitled to assess traders in possession of excise goods for excise duty where there is no evidence that the duty has been paid. When buying excisable products, businesses are advised to ensure that procedures are in place to evidence that a duty point has occurred and excise duty has been paid earlier in the supply chain.
ITU 10/2016
The document summarizes two key developments from the past week:
1) A Court of Justice ruling found that claims handling services provided to an insurer are not exempt from VAT as insurance transactions or related services. UK law will need to change and businesses providing these services should review their VAT position.
2) The UK budget announced new powers for HMRC to make online marketplaces jointly liable for VAT debts of overseas sellers on their platforms. This aims to reduce the estimated £365 million annual VAT loss from non-compliant foreign traders. Online portals will need to strengthen due diligence of sellers.
Vat Alert - reverse charge
Grant Thornton UK LLP is a member firm of Grant Thornton International Ltd, which provides assurance, tax, and advisory services through independent member firms. Grant Thornton UK LLP is a separate legal entity from other member firms. This document provides information about Grant Thornton but does not constitute legal advice and readers should consult professionals for guidance.
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UK: VAT use and enjoyment on advertising services?
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Fischvierterl am Naschmarkt - Certificate of Service
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Existen tres tipos principales de redes inalámbricas según su cobertura: redes personales inalámbricas (WPAN), redes metropolitanas inalámbricas (WMAN) y redes de área amplia inalámbricas (WWAN). Las WPAN tienen un alcance personal y usan tecnologías como Bluetooth y ZigBee. Las WMAN cubren áreas metropolitanas usando WiMAX u otros sistemas como LMDS. Por último, las WWAN usan tecnologías celulares como WiMAX, UMTS, GPRS para transferir datos
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This document provides information about a GSM signal booster from Dolphin Automation & Technology. It describes the product as a KW17A-GSM repeater that amplifies mobile signals in the 890-915MHz and 935-960MHz bands. It also explains how signal boosters work to receive a low signal from a base station, amplify it, and retransmit the signal to provide stronger coverage for mobile phones. Basic installation instructions are provided involving testing signal strength outside, installing antennas, running cable, and powering on the booster. Contact information is given for inquiries.
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Similar to Case alert Isle of Wight - Court of Appeal
ITU 35/2015
This document summarizes three indirect tax cases:
1) The Court of Appeal ruled in favor of HMRC in a long-running case about whether VAT applied to off-street car parking provided by local authorities.
2) The Court of Appeal dismissed an appeal by Leeds City Council seeking refunds of VAT paid between 1996 and 2006, finding the three-year limitation period was valid.
3) The First-Tier Tax Tribunal dismissed an appeal by National Car Parks seeking a refund of VAT paid on voluntary overpayments made at parking machines, determining the overpayments constituted consideration for parking.
ITU 17/2016
The Court of Justice ruled against Bookit Ltd and the National Exhibition Centre (NEC) in two cases involving VAT exemption on card handling and payment processing fees. The Court determined that the taxpayers' actions in processing card payments and exchanging payment information did not constitute a financial service under the VAT Directive since they did not directly debit or credit accounts. As a result, the fees were subject to VAT rather than exempt. This ruling went against the taxpayers' arguments and means they and other businesses must pay VAT on similar card handling income.
ITU 34/2016
The document summarizes three recent tax cases:
1) A UK tribunal ruled that a company conducting a management buyout could reclaim VAT on professional fees, as it was part of a VAT group whose overall activities were taxable. This prevents HMRC from isolating an entity within a VAT group.
2) An EU court advisor said Hungary cannot deny a taxpayer's VAT recovery after incorrectly applying the reverse charge mechanism, as that violates neutrality.
3) An EU court ruled that prize money for racehorses was not subject to VAT, and related training costs were deductible overhead, since the horses promoted the business. The training services themselves were taxed at the standard rate.
Indirect Tax Update 18/2015
The Supreme Court ruled that a VAT avoidance scheme used by car retailer Pendragon was an abuse of EU law. Under the scheme, Pendragon claimed to sell used cars under the margin scheme even though it had deducted input VAT on the original purchases. The Supreme Court found this violated the purpose of the VAT Directive by giving Pendragon an illegitimate tax advantage. Additionally, two First-tier Tribunal cases were summarized: one ruled motor homes could not be treated as zero-rated caravans for VAT purposes due to their ability to move under own power. The other found the transfer of an opted property did not qualify as a transfer of a business due to the purchaser failing to properly opt to tax.
ITU 13/2017
The Advocate General issued an opinion that playing Bridge is a sport for VAT purposes and should qualify for VAT exemption. The Upper Tribunal ruled that voluntary overpayments for parking are subject to VAT. The First-tier Tribunal found that differing VAT treatment of welfare services providers in the UK and EU violates neutrality and the UK law is invalid.
Indirect Tax Update 40/2014
The Upper Tribunal upheld the First-tier Tribunal's decision that the taxpayer failed to demonstrate that paying the disputed tax would cause hardship. As a result, the taxpayer must either pay the tax or withdraw its appeal. This case concerned VAT payments on mobile phones in 2006. HMRC claimed the phone model was not actually available then and assessed the taxpayer to recover the VAT. After years of litigation over hardship appeal rights, the Upper Tribunal dismissed all of the taxpayer's arguments, agreeing with the First-tier Tribunal's original decision. The taxpayer may now either pay the tax or withdraw its appeal.
ITU 16/2016
Three UK court cases were summarized:
1) The UK Supreme Court ruled in Airtours v HMRC that a company was not entitled to deduct VAT payments on professional services supplied to banks, not the company, even though the company paid the fees.
2) The Court of Appeal dismissed an appeal by the University of Huddersfield relating to a VAT planning arrangement for building works, finding the arrangement was an abusive tax scheme.
3) The Court of Justice ruled that bus fares charged by a local authority were outside the scope of VAT and not an economic activity, since only 3% of costs were covered by parental contributions.
ITU 25/2016
This document summarizes three indirect tax cases:
1) The Court of Justice ruled that imposing VAT on legal fees in Belgium did not violate rights to an effective remedy or equality, as the VAT amount was not large enough to prevent access to justice.
2) The Court also ruled that using helicopters for flight training in Germany was not a "commercial use" and was therefore eligible for temporary import tax relief.
3) UK's Upper Tribunal dismissed an HMRC appeal and ruled that a rugby club's sports pavilion qualified for VAT zero-rating as a "village hall" despite being run only by the club.
ITU 32/2015
The UK Court of Appeal referred the long-running Mercedes-Benz Financial Services VAT case to the Court of Justice of the European Union to determine the meaning of "in the normal course of events" regarding whether a supply is of goods or services. A decision is not expected for several years. Additionally, the CJEU clarified import classification for temperature indicators, and the UK Tax Tribunal upheld two HMRC demands for security payments as conditions for taxpayers to continue trading, finding HMRC acted reasonably given the companies' histories.
ITU 332015
The First-tier Tax Tribunal issued a controversial decision ruling that VAT is due on the full consideration received by Adecco UK Ltd and others for supplying temporary workers to clients, contradicting an earlier similar case. The Court of Appeal decided to refer the Brockenhurst College case on whether supplies of catering and performances are 'closely related' to education to the European Court of Justice for guidance. The FTT also ruled in the golf clubs unjust enrichment case that 90% of VAT claims made should be repaid, constituting a major victory for the golf clubs against HMRC's position.
ITU 15/2016
The document discusses proposed changes to VAT rules for advertising services supplied between EU and non-EU businesses. Currently, advertising services supplied to a business outside the EU do not incur EU VAT. HMRC proposes to introduce a "use and enjoyment" rule so that VAT is determined by where the advertising is targeted and consumed, not just the customer's location. However, key terms are undefined and many questions remain around implementation, such as how to determine and verify use and enjoyment location. HMRC will consult further over the summer and aims to introduce draft legislation by late 2016.
Indirect Tax Update 10 May 2016
This weeks ITU looks at the VAT rules changes for advertising. The basic VAT place of supply rules – the rules that determine where a supply of goods or services takes place – sometimes lead to an outcome which results in supplies not being taxed at all. As an example, the place of supply of advertising services is currently where the customer belongs. If this is not within the EU, then no EU VAT is charged by an EU supplier even though the advertisement in question may be targeted at EU consumers.
HMRC has begun a consultation process which may lead to the imposition of a 'use and enjoyment' rule which, it hopes, will ensure that, in such circumstances, the place of supply will be determined by reference to where the service is targeted and consumed rather than simply where the customer is established.
Indirect Tax Update 19/2015
HMRC has issued a brief responding to two recent court losses on VAT issues. It does not agree with a Court of Appeal decision that compound interest is owed on VAT refunds and will seek to appeal to the Supreme Court. It also lost an appeal at the Upper Tribunal regarding input VAT recovery for management fees related to the University of Cambridge's endowment fund. The Upper Tribunal affirmed the fees were overhead costs for the University's non-business activities.
ITU 21/2016
The Upper Tribunal considered two cases related to VAT. In the first case, Zipvit lost its appeal in claiming VAT reimbursement from Royal Mail. The Upper Tribunal determined that without a valid VAT invoice, Zipvit had no right to reclaim input tax, even though VAT may have been properly chargeable. In the second case, the First-Tier Tribunal ruled that denying the same VAT exemption for welfare services to a for-profit organization as granted to charities violated the EU principle of fiscal neutrality. Additionally, the Upper Tribunal dismissed HMRC's appeal in the Imperial College case, requiring HMRC to abide by the terms of its original special VAT reimbursement agreement with universities.
Indirect Tax Update 02/2016
HMRC has announced a consultation on expanding eligibility for UK VAT groups following recent EU court rulings. Currently, only corporate bodies under common control can form a UK VAT group. The consultation will consider allowing partnerships and other entities to join VAT groups in order to comply with EU law. HMRC will consult with trade groups before developing policy options for broader consultation later in the year. The changes are aimed at aligning UK VAT law with the EU principle of fiscal neutrality established in recent court cases.
ITU 33/2016
The document summarizes two recent UK Upper Tribunal cases and an announcement from HMRC. The first case involved whether subsidiaries of a college could claim eligibility for VAT exemption like the college. The Tribunal confirmed they could not without express provisions preventing profit distribution in their constitutional documents. The second case involved three truck drivers transporting smuggled alcohol. The Tribunal held the drivers were deemed to be 'holding' the goods and liable for unpaid excise duty. HMRC also clarified its policy on recovering input VAT incurred before VAT registration within certain time limits.
Indirect Tax Update 07/2015
The document summarizes three indirect tax cases from the First-tier Tribunal (FTT). The first case discusses Taylor Wimpey PLC's loss in its battle against HMRC regarding VAT on "white goods" supplied with new homes. The second case discusses the FTT ruling that reward payments for achieving sales targets can reduce the taxable amount for VAT purposes. The third case summarizes additional FTT decisions regarding partial VAT exemption methods and late filing of VAT refund appeals.
ITU 01/2016
The document summarizes three indirect tax cases:
1) The Court of Justice ruled that airlines must pay VAT on fares retained from passengers who do not board flights ("no-shows"), as the fares are consideration for the transport contract and not a compensation payment.
2) The First-tier Tribunal ruled that motor dealers' demonstrator cars are not capital goods for VAT purposes, meaning the value of their sales must be included in partial exemption calculations, potentially reducing dealers' historic VAT refund claims.
3) The Upper Tribunal ruled that bingo operators do not owe bingo duty on fees charged for electronic bingo devices, as the fees are for device rental rather than participation in bingo games.
ITU 20/2016
1) The Upper Tribunal ruled that the transfer of a business into a VAT group can qualify as a transfer of a going concern (TOGC), meaning no VAT is due. This contradicted HMRC's previous policy.
2) HMRC has now reversed its policy in line with the Upper Tribunal's ruling, stating in Revenue & Customs Brief 11/2016 that transfers into and out of a VAT group can be TOGCs if certain conditions are met.
3) A First-tier Tax Tribunal case involved a company that paid VAT on wind turbines from a supplier that went into administration before delivering the goods. The tribunal ruled the company could not reclaim the VAT since the turbines were not supplied.
Indirect Tax Update 12/2015
1) HMRC has issued new guidance on employers recovering VAT on pension fund management costs. The guidance recognizes that due to the unique structure of UK pension schemes, employers can reclaim VAT if they meet certain conditions, such as directly paying the fund manager.
2) An advocate general opinion found that holding companies can fully recover VAT on costs related to acquiring subsidiaries and raising capital as long as the activities are directly linked to the company's overall economic activities.
3) A tribunal case confirmed that for VAT purposes, the value of a part exchange vehicle in a new car sale is the amount agreed between the dealer and customer, not any estimated market value.
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ITU 10/2018
The document summarizes three recent court cases related to indirect tax:
1) The Court of Justice of the European Union ruled that a holding company letting property to its subsidiary constituted involvement in management, allowing the holding company to reclaim input tax on acquisition costs.
2) The UK Supreme Court ruled that a company that left a VAT group was not acting as an agent of the group when it later claimed a VAT refund, and thus the representative member of the VAT group was not entitled to the refund.
3) The UK Court of Session ruled that the supply of temporary modular classrooms was a taxable service, not a supply of an interest in land that would be VAT exempt, as the company had no interest in
ITU 07/2018
The document summarizes several indirect tax cases from the UK.
The first case discusses an Advocate General's opinion in a case referred to the Court of Justice by the Irish Supreme Court involving Ryanair's attempt to reclaim VAT fees from an unsuccessful takeover bid of Aer Lingus. The Advocate General believes Ryanair is entitled to reclaim the VAT.
The second case discusses a First-Tier Tax Tribunal case involving Marks & Spencer's "Dine In for £10 with free wine" promotion. The tribunal agreed with HMRC that VAT was due on the wine as customers paid for a package including the wine.
The third case discusses a First-Tier Tax Tribunal case involving a Guern
Case alert: Summit Electrical Installations Ltd Upper Tribunal Judgment
Whether services can be zero-rated when supplied to a main contractor. Whether planning restrictions on occupation prevents zero-rating
ITU 08/2018
The document summarizes two recent indirect tax cases in the UK:
1) HMRC v Summit Electrical Installations Ltd - The Upper Tribunal dismissed HMRC's appeal and agreed with the First-tier Tax Tribunal's decision that the taxpayer could zero-rate its electrical installation services for a new student accommodation building, as the building qualified as a dwelling under VAT law.
2) Bratt Autoservices Ltd - The Court of Appeal dismissed the taxpayer's appeal and agreed with the Upper Tribunal that the taxpayer's 2009 VAT repayment claim was not valid because it did not allocate amounts to the taxpayer's prescribed accounting periods as required by VAT law.
Vat Alert: Reverse Charge on Construction Services
The document discusses HMRC's proposal to introduce a 'reverse charge mechanism' for VAT on construction services to combat VAT fraud in the industry. Under the new rules, the customer would be responsible for accounting for VAT on supplies received rather than the supplier. This would prevent suppliers from charging VAT but not paying it over to HMRC. The draft legislation provides a wide definition of construction services that would be subject to the reverse charge, including building works, repairs, and various site works. While measures to tackle fraud are necessary, commentators note that the broad scope means nearly all subcontracted construction services would be affected, with wider impacts than originally planned.
ITU 09/2018
The document summarizes three recent indirect tax cases:
1) Wetheralds Ltd - The Upper Tribunal ruled that a thermally efficient roofing system was a supply of a new roof rather than insulation materials, and was thus subject to the standard VAT rate of 20% rather than the reduced 5% rate.
2) Abbotsley Ltd - The Upper Tribunal confirmed that affiliation fees paid by proprietary golf clubs to golf associations were exempt from VAT as being essential to sport.
3) Hutchison 3G UK Ltd - The First-tier Tax Tribunal dismissed H3G's argument that the tax point for mobile phone contracts should be when services are used rather than when monthly payments are received.
ITU 06/2018
The document provides summaries of three recent court rulings related to indirect tax:
1) The Advocate General issued an opinion in Volkswagen Financial Services v HMRC, finding that vehicle financing arrangements constitute a single taxable supply of a vehicle, entitling the company to full VAT recovery on overheads. This contradicts the UK's view of separate taxable and exempt supplies.
2) The Court of Appeal ruled against Wakefield College in its claim that education provided to students paying partial fees due to financial hardship was not an "economic activity" subject to VAT, as the partial fees constitute remuneration rather than consideration.
3) The Upper Tribunal dismissed HMRC's argument that payments by Marriott
Case Alert - University of Cambridge
The document summarizes a court case between the University of Cambridge and HMRC regarding whether the University can reclaim VAT incurred on fund management fees. The University operates an endowment fund managed by a third party, which charges fees. The University argues these fees are overheads that can be partially reclaimed under its partial exemption special method. HMRC argues the fees are consumed by investment activities and not reclaimable. Lower courts sided with the University, but the Court of Appeal referred the case to the European Court of Justice for guidance on interpreting relevant VAT directives and prior cases.
Vat Alert - Cost Sharing Groups
HMRC has announced changes to the UK's VAT rules relating to cost sharing groups (CSGs) following recent judgments from the Court of Justice of the European Union. The changes mean the VAT exemption for CSGs will now only apply to entities providing certain public interest services listed in the VAT Directive, such as postal, education, and health services. Banking and insurance entities are no longer eligible. HMRC will also restrict CSG membership to UK entities and require recharges to members be made only at cost. Entities correctly applying previous guidance have until the end of May 2018 to comply with the new rules.
ITU 05/2018
HMRC revises its policy in relation to cost sharing groups following judgments from the Court of Justice. Specifically, HMRC will no longer allow the cost sharing exemption for financial and insurance businesses as the Court of Justice ruled the exemption is not available to these sectors. HMRC will provide a two month transition period for affected businesses to regularize their VAT positions. Additionally, the Court of Appeal case involves determining whether VAT on fund management services provided to the University of Cambridge's endowment fund can be attributed to the overall activities of the University.
Case Alert - VWFS - Advocate General's opinion
This document summarizes an Advocate General's opinion in a case between HMRC and Volkswagen Financial Services (UK) Ltd regarding VAT treatment of hire purchase agreements. The Advocate General opined that input VAT incurred by VWFS on overheads cannot be recovered as it relates to the exempt supply of credit. However, the UK's treatment of hire purchase transactions as two separate supplies is incorrect under EU law - they should be treated as a single taxable supply of a car with an incidental credit element. If the court agrees, it would entitle VWFS to recover all input VAT but require accounting for output tax on interest charged. The opinion creates uncertainty for finance industry VAT treatment going forward.
Case Alert - Wakefield College - Court of Appeal
The Court of Appeal unanimously dismissed Wakefield College's appeal of a decision that denied VAT zero-rating for the construction of a new college building. While most of the College's students either paid no or subsidized fees, the Court found this still constituted consideration for education and made it an economic activity, precluding VAT zero-rating. The Court distinguished consideration under VAT Directive Article 2 from remuneration under Article 9, finding the College's activities were remunerated and economic in nature. This clarified that satisfying Article 2's consideration test does not automatically deem an activity non-economic under Article 9. The College's attempt to analogize to a prior legal aid case was rejected.
Case alert - Ryanair - Advocate General's opinion
This summary provides the key details from the document in 3 sentences:
The document discusses an Advocate General's opinion in a case referred to the Court of Justice of the European Union concerning whether the Irish airline Ryanair was entitled to reclaim VAT incurred on professional fees relating to its failed 2006 bid to acquire rival airline Aer Lingus. The Advocate General considers that Ryanair is entitled to reclaim the input VAT, both because there was an intention to provide management services and because the cost of acquiring Aer Lingus shares was to directly and permanently extend Ryanair's taxable air passenger transport services business. This is the case even though the takeover bid was ultimately blocked and the management services were not provided.
ITU 06/2018
The document provides summaries of three recent court rulings related to indirect tax:
1) The Advocate General issued an opinion in Volkswagen Financial Services v HMRC, finding that vehicle financing arrangements constitute a single taxable supply of a vehicle, allowing the company to recover input tax on overheads.
2) The Court of Appeal ruled against Wakefield College in its claim that education provided to students paying partial fees was not an economic activity for VAT purposes, as the partial fees constitute consideration.
3) The Upper Tribunal dismissed HMRC's argument that payments by Marriott Rewards to redeeming hotels were third party consideration, but also ruled that neither Marriott nor Whitbread established the UK or US
Case Alert - Marks & Spencer
This document discusses a case regarding a promotional offer by Marks & Spencer (M&S) where customers could purchase three food items for £10 and receive a free bottle of wine. HMRC considered that the deal was actually for four items for £10 and that VAT should be paid on the portion of the £10 attributable to the wine. The First-tier Tax Tribunal agreed with HMRC's view, finding that the economic reality was a package deal rather than items plus a free gift. It determined that the £10 payment should be apportioned with VAT paid on the wine portion. The Tribunal emphasized examining the commercial substance of promotions for accurate VAT determination.
Case Alert - Marriott Rewards / Whitbread - Upper Tribunal
The Upper Tribunal issued a judgment regarding the VAT treatment of payments made through Marriott's customer loyalty rewards scheme. The Tribunal determined that payments from Marriott Rewards LLC to participating hotels were consideration for redemption services provided to MRL, rather than third-party consideration for accommodation supplied to customers. It also found that these redemption services constituted a supply of services related to land in the UK, rather than advertising services, meaning UK VAT was due. Both MRL and Whitbread's appeals were dismissed.
ITU 04/2018
The document provides updates on recent indirect tax cases from the UK courts, CJEU, and Brexit developments.
The CJEU issued an opinion in DPAS Ltd, finding that DPAS's service of collecting payments from patients and transferring them to dentists was not exempt from VAT as a payment transaction, but rather a taxable debt collection service, even though the contracts were amended to provide the service to patients rather than dentists.
The CJEU also ruled in a case from Slovakia that when a supplier issues supplementary VAT invoices to correct an underpayment of VAT, the time limit for claiming VAT refunds should run from the date of the supplementary invoices, not the original supplies.
Finally,
Case Alert DPAS Ltd - Advocate General's opinion
Whether collection of direct debits constitutes a transaction concerning payments or transfers and exempt from VAT - AG considers not
Brexit Alert
This document summarizes an agreement reached between the UK and EU to establish a transitional period after Brexit. Key points include:
- The UK will leave the EU in March 2019 but remain in the single market and customs union until December 2020.
- Goods moving between the UK and EU during this period will be treated as intra-EU trade in regards to customs and VAT.
- The agreement provides businesses more certainty and time to prepare for changes taking effect after the transitional period ends. However, the deal still requires approval from all EU member states.
Case Alert: Kreuzmayr CJEU Judgment
CJEU issues judgment on place of supply issue relating to two supplies but a single transportation - Also deals with recovery of incorrectly charged input VAT
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5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
Discover the Future of Dogecoin with Our Comprehensive Guidance
Learn in-depth about Dogecoin's trajectory and stay informed with 36crypto's essential and up-to-date information about the crypto space.
Our presentation delves into Dogecoin's potential future, exploring whether it's destined to skyrocket to the moon or face a downward spiral. In addition, it highlights invaluable insights. Don't miss out on this opportunity to enhance your crypto understanding!
https://36crypto.com/the-future-of-dogecoin-how-high-can-this-cryptocurrency-reach/
Independent Study - College of Wooster Research (2023-2024)
"Does Foreign Direct Investment Negatively Affect Preservation of Culture in the Global South? Case Studies in Thailand and Cambodia."
Do elements of globalization, such as Foreign Direct Investment (FDI), negatively affect the ability of countries in the Global South to preserve their culture? This research aims to answer this question by employing a cross-sectional comparative case study analysis utilizing methods of difference. Thailand and Cambodia are compared as they are in the same region and have a similar culture. The metric of difference between Thailand and Cambodia is their ability to preserve their culture. This ability is operationalized by their respective attitudes towards FDI; Thailand imposes stringent regulations and limitations on FDI while Cambodia does not hesitate to accept most FDI and imposes fewer limitations. The evidence from this study suggests that FDI from globally influential countries with high gross domestic products (GDPs) (e.g. China, U.S.) challenges the ability of countries with lower GDPs (e.g. Cambodia) to protect their culture. Furthermore, the ability, or lack thereof, of the receiving countries to protect their culture is amplified by the existence and implementation of restrictive FDI policies imposed by their governments.
My study abroad in Bali, Indonesia, inspired this research topic as I noticed how globalization is changing the culture of its people. I learned their language and way of life which helped me understand the beauty and importance of cultural preservation. I believe we could all benefit from learning new perspectives as they could help us ideate solutions to contemporary issues and empathize with others.
做澳洲澳大利亚国立大学毕业证荣誉学位证书原版一模一样
原版一模一样【微信：741003700 】【澳洲澳大利亚国立大学毕业证荣誉学位证书】【微信：741003700 】学位证，留信认证（真实可查，永久存档）offer、雅思、外壳等材料/诚信可靠,可直接看成品样本，帮您解决无法毕业带来的各种难题！外壳，原版制作，诚信可靠，可直接看成品样本。行业标杆！精益求精，诚心合作，真诚制作！多年品质 ,按需精细制作，24小时接单,全套进口原装设备。十五年致力于帮助留学生解决难题，包您满意。
本公司拥有海外各大学样板无数，能完美还原海外各大学 Bachelor Diploma degree, Master Degree Diploma
1:1完美还原海外各大学毕业材料上的工艺：水印，阴影底纹，钢印LOGO烫金烫银，LOGO烫金烫银复合重叠。文字图案浮雕、激光镭射、紫外荧光、温感、复印防伪等防伪工艺。材料咨询办理、认证咨询办理请加学历顾问Q/微741003700
留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
Independent Study - College of Wooster Research (2023-2024) FDI, Culture, Glo...
Independent Study - College of Wooster Research (2023-2024) FDI, Culture, Glo...AntoniaOwensDetwiler
"Does Foreign Direct Investment Negatively Affect Preservation of Culture in the Global South? Case Studies in Thailand and Cambodia."
Do elements of globalization, such as Foreign Direct Investment (FDI), negatively affect the ability of countries in the Global South to preserve their culture? This research aims to answer this question by employing a cross-sectional comparative case study analysis utilizing methods of difference. Thailand and Cambodia are compared as they are in the same region and have a similar culture. The metric of difference between Thailand and Cambodia is their ability to preserve their culture. This ability is operationalized by their respective attitudes towards FDI; Thailand imposes stringent regulations and limitations on FDI while Cambodia does not hesitate to accept most FDI and imposes fewer limitations. The evidence from this study suggests that FDI from globally influential countries with high gross domestic products (GDPs) (e.g. China, U.S.) challenges the ability of countries with lower GDPs (e.g. Cambodia) to protect their culture. Furthermore, the ability, or lack thereof, of the receiving countries to protect their culture is amplified by the existence and implementation of restrictive FDI policies imposed by their governments.
My study abroad in Bali, Indonesia, inspired this research topic as I noticed how globalization is changing the culture of its people. I learned their language and way of life which helped me understand the beauty and importance of cultural preservation. I believe we could all benefit from learning new perspectives as they could help us ideate solutions to contemporary issues and empathize with others.Economic Risk Factor Update: June 2024 [SlideShare]
May’s reports showed signs of continued economic growth, said Sam Millette, director, fixed income, in his latest Economic Risk Factor Update.
For more market updates, subscribe to The Independent Market Observer at https://blog.commonwealth.com/independent-market-observer.
高仿英国伦敦艺术大学毕业证（ual毕业证书）文凭证书原版一模一样
原版一模一样【微信：741003700 】【英国伦敦艺术大学毕业证（ual毕业证书）文凭证书】【微信：741003700 】学位证，留信认证（真实可查，永久存档）offer、雅思、外壳等材料/诚信可靠,可直接看成品样本，帮您解决无法毕业带来的各种难题！外壳，原版制作，诚信可靠，可直接看成品样本。行业标杆！精益求精，诚心合作，真诚制作！多年品质 ,按需精细制作，24小时接单,全套进口原装设备。十五年致力于帮助留学生解决难题，包您满意。
本公司拥有海外各大学样板无数，能完美还原海外各大学 Bachelor Diploma degree, Master Degree Diploma
1:1完美还原海外各大学毕业材料上的工艺：水印，阴影底纹，钢印LOGO烫金烫银，LOGO烫金烫银复合重叠。文字图案浮雕、激光镭射、紫外荧光、温感、复印防伪等防伪工艺。材料咨询办理、认证咨询办理请加学历顾问Q/微741003700
留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
1比1复刻(ksu毕业证书)美国堪萨斯州立大学毕业证本科文凭证书原版一模一样
原版定制【微信:bwp0011】《(ksu毕业证书)美国堪萨斯州立大学毕业证本科文凭证书》【微信:bwp0011】成绩单 、雅思、外壳、留信学历认证永久存档查询，采用学校原版纸张、特殊工艺完全按照原版一比一制作（包括：隐形水印，阴影底纹，钢印LOGO烫金烫银，LOGO烫金烫银复合重叠，文字图案浮雕，激光镭射，紫外荧光，温感，复印防伪）行业标杆！精益求精，诚心合作，真诚制作！多年品质 ,按需精细制作，24小时接单,全套进口原装设备，十五年致力于帮助留学生解决难题，业务范围有加拿大、英国、澳洲、韩国、美国、新加坡，新西兰等学历材料，包您满意。
【业务选择办理准则】
一、工作未确定，回国需先给父母、亲戚朋友看下文凭的情况，办理一份就读学校的毕业证【微信bwp0011】文凭即可
二、回国进私企、外企、自己做生意的情况，这些单位是不查询毕业证真伪的，而且国内没有渠道去查询国外文凭的真假，也不需要提供真实教育部认证。鉴于此，办理一份毕业证【微信bwp0011】即可
三、进国企，银行，事业单位，考公务员等等，这些单位是必需要提供真实教育部认证的，办理教育部认证所需资料众多且烦琐，所有材料您都必须提供原件，我们凭借丰富的经验，快捷的绿色通道帮您快速整合材料，让您少走弯路。
留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
【关于价格问题（保证一手价格）】
我们所定的价格是非常合理的，而且我们现在做得单子大多数都是代理和回头客户介绍的所以一般现在有新的单子 我给客户的都是第一手的代理价格，因为我想坦诚对待大家 不想跟大家在价格方面浪费时间
对于老客户或者被老客户介绍过来的朋友，我们都会适当给一些优惠。
Ending stagnation: How to boost prosperity across Scotland
A toxic combination of 15 years of low growth, and four decades of high inequality, has left Britain poorer and falling behind its peers. Productivity growth is weak and public investment is low, while wages today are no higher than they were before the financial crisis. Britain needs a new economic strategy to lift itself out of stagnation.
Scotland is in many ways a microcosm of this challenge. It has become a hub for creative industries, is home to several world-class universities and a thriving community of businesses – strengths that need to be harness and leveraged. But it also has high levels of deprivation, with homelessness reaching a record high and nearly half a million people living in very deep poverty last year. Scotland won’t be truly thriving unless it finds ways to ensure that all its inhabitants benefit from growth and investment. This is the central challenge facing policy makers both in Holyrood and Westminster.
What should a new national economic strategy for Scotland include? What would the pursuit of stronger economic growth mean for local, national and UK-wide policy makers? How will economic change affect the jobs we do, the places we live and the businesses we work for? And what are the prospects for cities like Glasgow, and nations like Scotland, in rising to these challenges?
Tdasx: In-Depth Analysis of Cryptocurrency Giveaway Scams and Security Strate...
Tdasx: In-Depth Analysis of Cryptocurrency Giveaway Scams and Security Strategies
Detailed power point presentation on compound interest and how it is calculated
Detailed information about compund interest
Accounting Information Systems (AIS).pptx
An accounting information system (AIS) refers to tools and systems designed for the collection and display of accounting information so accountants and executives can make informed decisions.
真实可查(nwu毕业证书)美国西北大学毕业证学位证书范本原版一模一样
原版定制【微信:bwp0011】《(nwu毕业证书)美国西北大学毕业证学位证书》【微信:bwp0011】成绩单 、雅思、外壳、留信学历认证永久存档查询，采用学校原版纸张、特殊工艺完全按照原版一比一制作（包括：隐形水印，阴影底纹，钢印LOGO烫金烫银，LOGO烫金烫银复合重叠，文字图案浮雕，激光镭射，紫外荧光，温感，复印防伪）行业标杆！精益求精，诚心合作，真诚制作！多年品质 ,按需精细制作，24小时接单,全套进口原装设备，十五年致力于帮助留学生解决难题，业务范围有加拿大、英国、澳洲、韩国、美国、新加坡，新西兰等学历材料，包您满意。
【业务选择办理准则】
一、工作未确定，回国需先给父母、亲戚朋友看下文凭的情况，办理一份就读学校的毕业证【微信bwp0011】文凭即可
二、回国进私企、外企、自己做生意的情况，这些单位是不查询毕业证真伪的，而且国内没有渠道去查询国外文凭的真假，也不需要提供真实教育部认证。鉴于此，办理一份毕业证【微信bwp0011】即可
三、进国企，银行，事业单位，考公务员等等，这些单位是必需要提供真实教育部认证的，办理教育部认证所需资料众多且烦琐，所有材料您都必须提供原件，我们凭借丰富的经验，快捷的绿色通道帮您快速整合材料，让您少走弯路。
留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
【关于价格问题（保证一手价格）】
我们所定的价格是非常合理的，而且我们现在做得单子大多数都是代理和回头客户介绍的所以一般现在有新的单子 我给客户的都是第一手的代理价格，因为我想坦诚对待大家 不想跟大家在价格方面浪费时间
对于老客户或者被老客户介绍过来的朋友，我们都会适当给一些优惠。
1：1制作加拿大麦吉尔大学毕业证硕士学历证书原版一模一样
原版一模一样【微信：741003700 】【加拿大麦吉尔大学毕业证硕士学历证书】【微信：741003700 】学位证，留信认证（真实可查，永久存档）offer、雅思、外壳等材料/诚信可靠,可直接看成品样本，帮您解决无法毕业带来的各种难题！外壳，原版制作，诚信可靠，可直接看成品样本。行业标杆！精益求精，诚心合作，真诚制作！多年品质 ,按需精细制作，24小时接单,全套进口原装设备。十五年致力于帮助留学生解决难题，包您满意。
本公司拥有海外各大学样板无数，能完美还原海外各大学 Bachelor Diploma degree, Master Degree Diploma
1:1完美还原海外各大学毕业材料上的工艺：水印，阴影底纹，钢印LOGO烫金烫银，LOGO烫金烫银复合重叠。文字图案浮雕、激光镭射、紫外荧光、温感、复印防伪等防伪工艺。材料咨询办理、认证咨询办理请加学历顾问Q/微741003700
留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
在线办理(GU毕业证书)美国贡萨加大学毕业证学历证书一模一样
学校原件一模一样【微信：741003700 】《(GU毕业证书)美国贡萨加大学毕业证学历证书》【微信：741003700 】学位证，留信认证（真实可查，永久存档）原件一模一样纸张工艺/offer、雅思、外壳等材料/诚信可靠,可直接看成品样本，帮您解决无法毕业带来的各种难题！外壳，原版制作，诚信可靠，可直接看成品样本。行业标杆！精益求精，诚心合作，真诚制作！多年品质 ,按需精细制作，24小时接单,全套进口原装设备。十五年致力于帮助留学生解决难题，包您满意。
本公司拥有海外各大学样板无数，能完美还原。
1:1完美还原海外各大学毕业材料上的工艺：水印，阴影底纹，钢印LOGO烫金烫银，LOGO烫金烫银复合重叠。文字图案浮雕、激光镭射、紫外荧光、温感、复印防伪等防伪工艺。材料咨询办理、认证咨询办理请加学历顾问Q/微741003700
【主营项目】
一.毕业证【q微741003700】成绩单、使馆认证、教育部认证、雅思托福成绩单、学生卡等！
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三.真实教育部学历学位认证（教育部存档！教育部留服网站永久可查）
四.办理各国各大学文凭(一对一专业服务,可全程监控跟踪进度)
如果您处于以下几种情况：
◇在校期间，因各种原因未能顺利毕业……拿不到官方毕业证【q/微741003700】
◇面对父母的压力，希望尽快拿到；
◇不清楚认证流程以及材料该如何准备；
◇回国时间很长，忘记办理；
◇回国马上就要找工作，办给用人单位看；
◇企事业单位必须要求办理的
◇需要报考公务员、购买免税车、落转户口
◇申请留学生创业基金
留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
The Impact of Generative AI and 4th Industrial Revolution
This infographic explores the transformative power of Generative AI, a key driver of the 4th Industrial Revolution. Discover how Generative AI is revolutionizing industries, accelerating innovation, and shaping the future of work.
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Case alert Isle of Wight - Court of Appeal
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