The tax bulletin informs about the most important developments in the field of taxes all over the world.

1. CONTENTS
▶▶ SOUTH AFRICA
New VAT registration requirement for
foreign e-commerce businesses 1
▶▶ EDITOR’S LETTER 2
▶▶ BELGIUM
Belgian VAT: new clarifications regarding
e-invoicing 2
▶▶ GERMANY
VAT grouping developments 3
▶▶ GHANA
New VAT Act introduced 4
▶▶ LATVIA
VAT amendments regarding electronically
supplied services 4
▶▶ LUXEMBOURG
VAT rate increases on the way 5
▶▶ NETHERLANDS
Dutch AG issues opinion on deduction
of VAT on vacant immovable property 6
▶▶ NEW ZEALAND
GST: claims by non-resident businesses &
tooling costs 7
▶▶ ROMANIA
EU VAT refunds: application of former
8th
Directive to non-resident with
Romanian Tax representative 8
▶▶ SINGAPORE
Goods and Services Tax (GST) updates for
the fund management industry 9
▶▶ SPAIN
VAT – Directorate general of taxation tax
ruling n° V0445-14 10
▶▶ SWITZERLAND
Swiss Supreme Court says U.S. dating
website operator must register for VAT 10
▶▶ UNITED KINGDOM
Report on the world customs organisation’s
Authorised Economic Operator Conference 11
▶▶ UNITED STATES
Sales tax systems in the USA – an overview 12
LUXEMBOURG
VAT rate increases on the way
READ MORE 5
NEW ZEALAND
GST: claims by non-resident businesses
& tooling costs
READ MORE 7
JULY 2014 ISSUE 2
WWW.BDOINTERNATIONAL.COM
INDIRECT TAX NEWS
SOUTH AFRICANEW VAT REGISTRATION REQUIREMENT FOR FOREIGN E-COMMERCE
BUSINESSES
T
he rapid advances in Technology and
increases in e-commerce transactions
across the word in the last decade
have reached the South African shores and
South African consumers have increased their
consumption of goods and services acquired
over the internet.
Goods and services acquired over the internet
from local suppliers that are registered
as VAT vendors are subject to VAT at the
14% standard rate. Local suppliers must
charge VAT on their supplies and are required
to remit the VAT to the South African Revenue
Services (SARS).
Goods acquired from foreign suppliers are
subject to 14% VAT on importation into
South Africa. Local clients must bear the
14% VAT charge on goods imported in
South Africa. However, in respect of services,
and especially e-commerce services, SARS
used to require the local client to account for
and pay VAT on imported services (essentially
a reverse charge mechanism) acquired from
foreign suppliers. Enforcing compliance with
this requirement was virtually impossible.
This, in effect, made acquiring services and
e-commerce services supplied by foreign
suppliers more attractive, since they were
supplied at a lower cost than services acquired
from a local supplier.
To ensure parity between local and foreign
suppliers, and to address the issue of non-
compliance with VAT on imported services, the
South African VAT legislation was amended.
The amendments were made in regulations
that came into effect on 1 June 2014. The
amendments compel foreign suppliers of
“electronic services” to local clients to register
as VAT vendors in South Africa and to charge
14% VAT on the supply of these services.
A further requirement is that payment for
the e-service must be from an account with a
South African bank.
What are “electronic services”?
Obviously, the issue of whether services
provided by a foreign supplier constitute
“electronic services” is crucial. According to
the regulations, “electronic services” broadly
include the supply of:
• Educational services, such as internet-based
courses provided as part of an education
programme. However, there is an exception
where the service provider is registered with
an educational authority in the “export”
country;
• Games and games of chance, which include
electronic betting and wagering;
• Internet-based auction services;
• E-books, still pictures, music, and audio-
visual content;
• Subscription services, including, among
other things, magazines, newspapers,
journals, social networking services,
websites, and blogs.
Registration of foreign electronic e-service
suppliers
Foreign suppliers of e-services to local clients
are obliged to register for VAT at the end of the
month in which the total value of their taxable
supplies exceeds ZAR 50,000.
The requirements for the VAT registration
for foreign suppliers of e-services has been
streamlined to make registrations as easy
as possible and to encourage compliance.
Unlike with traditional VAT registrations in
South Africa, foreign suppliers of e-services
do not need to have a representative vendor
acting on their behalf in South Africa.
Furthermore, based on the fact that it is
expected that these entities will only have
output VAT liability, they do not need access
to a bank account in South Africa for purposes
of receiving VAT refunds.
SEELAN MUTHAYAN
South Africa – Johannesburg
smuthayan@bdo.co.za
UNITED STATES
Sales tax systems in the USA –
an overview
READ MORE 12

2. 2 INDIRECT TAX NEWS 2
Dear Readers,
G
reetings from Dublin where our
‘Irish’ summer is threatening to
arrive any day soon.
In advance of the summer holiday season,
the BDO VAT Centre of Excellence
Committee together with our colleagues
Rosario Estella, Nuria Hernández Redondo,
and Carlos Lopez from BDO Spain’s Madrid
Office are busy working on the agenda
and logistics for the forthcoming BDO
international VAT conference which will be
held in Madrid in mid-September 2014.
This annual two day conference attracts an
increasing number of BDO colleagues from
countries outside the European Union each
year with attendees expected from the
U.S., Canada, India, Australia, and hopefully
China, among other countries.
The conference event itself provides an
excellent opportunity for representatives
from BDO offices worldwide to meet to
discuss evolving indirect tax related issues
and to plan how best to work with each
other to ensure we provide a holistic,
seamless advisory service to our local and
international clients.
Each year we hope to set a higher standard
and I am excited that this year it seems
likely that we will have some representation
by our BDO Customs and international
Trade Advisory colleagues in Madrid.
In advance of same, I wish you all an
enjoyable and hopefully somewhat sunny
summer season and, as always, any feedback
you may wish to provide on how to make
this publication more relevant and user
friendly are welcome at ifeerick@bdo.ie.
Kind regards from Dublin.
IVOR FEERICK
Chair – BDO International VAT Centre of
Excellence Committee
Ireland – Dublin
ifeerick@bdo.ie
EDITOR’S
LETTER
T
he Belgian tax authorities issued a new
VAT circular letter (AAFisc Nr. 14/2014
dd. 04.04.2014) that comments on
modifications to the Belgian VAT legislation
resulting from the implementation of
the EU directive 2010/45/EU concerning
e-invoicing. This circular replaces all previous
comments from the tax authorities with
respect to e-invoicing. The modifications to
the VAT relating to e-invoicing entered into
force retroactively on 1 January 2013.
E-invoicing is clarified
In the circular, the Belgian tax authorities
confirmed the following:
• An electronic invoice is subject to the same
rules as a paper invoice;
• An invoice qualifies as an electronic invoice
when it is both received and issued in
any electronic format. (In other words,
the format is unrestricted and can be, for
example: XML, Word, PDF, and so on.)
Two additional conditions apply with regard
to e-invoices. The first condition is acceptance
of the electronic invoices by the receiver.
Acceptance can be implicit, such as through
payment of an electronic invoice without
objection. Note, however, that the tax
authorities prefer acceptance demonstrated
through a written agreement because of the
evidential value and because of the possibility
of making arrangements regarding the legal
requirements in advance.
The second condition obliges the taxpayer to
guarantee the following with respect to the
invoice: the authenticity of it, the integrity of
its content, and the readability. This condition
results in the following burden of proof:
• Proof that the supplier listed on the invoice
has effectively executed the transaction
(authenticity);
• Proof that the content of the invoice
cannot be altered after sending the invoice
(integrity);
• Proof that all items in the invoice are
clear (that there is not much room for
interpretation) and that the invoice will
remain readable during the period it must
be retained (in other words, while it is
achieved).
What is new in this circular is that there are
no restrictions on how the above guarantees
must be accomplished.
In the circular, the Belgian tax authorities
pay a great deal of attention to business
controls related to establishing a trustworthy
audit trail. Business controls are basically the
processes set in place to generate reliable
financial, accounting, and regulatory reporting
data. Given this focus on business controls, an
invoice is seen as part of a whole transaction,
rather than an isolated document.
Examples of business controls relevant to
invoicing are matching (which might involve
comparison of, for example, an order form,
a transport document, and an invoice) and
IT controls. The choice of which business
controls are used is left to the taxpayer,
though the controls should take into account
things like the taxpayer’s size, the activity of
the company, and so on. The language of the
circular makes it clear that audit trails are
essential when establishing the authenticity
and integrity of an invoice.
But with the circular also comes
uncertainty…
In the past, the use of EDI and (advanced)
electronic signatures were sufficient to
guarantee the requirements of authenticity
and integrity of an invoice. As per the circular,
this is no longer the case. Though the technical
means previously used keep their evidential
value, they should be supplemented with
evidence resulting from internal business
controls. Taxpayers must decide for
themselves whether their mix of technical
means and internal business controls are
sufficient. An additional item of evidence that
the tax authorities have accepted is an audit
certificate issued by an external auditor that
includes an assessment of the efficiency of the
taxpayer’s business controls.
Another important consideration is the fact
that the tax authorities will no longer make
(preliminary) decisions on the appropriateness
of processes or software packages used to
ensure authenticity, integrity, and readability
of invoices.
Conclusion
It’s in the taxpayer’s interest to keep as much
documentation as possible regarding the
business controls that establish an audit trail.
Companies should ensure their e-invoicing
procedures are compliant with the regulations,
particularly with regard to using internal and
external business controls. A starting point
is a cost-benefit analysis, where parameters
such as internal processes, technical costs, the
willingness of the contracting parties to use
e-invoices, and so on, are taken into account.
If you are considering switching to e-invoicing,
consult http://www.efactuur.belgium.be for
useful information about different systems of
e-invoicing, including discussion of their pros
and cons.
LIESBETH DEBUSSCHERE
ERWIN BOUMANS
Belgium – Brussels
liesbeth.debusschere@bdo.be
erwin.boumans@bdo.be
BELGIUMBELGIAN VAT: NEW CLARIFICATIONS REGARDING E-INVOICING

3. 3INDIRECT TAX NEWS 2
GERMANYVAT GROUPING DEVELOPMENTS
O
n 5 May 2014, the German Federal
Ministry of Finance stated its current
position in respect of the inclusion of
non-taxable persons as part of a VAT group.
In addition, it has commented on the person
of an executive employee with regard to
the organisational link as requirement for a
German VAT group.
Non-taxable persons
The German Federal Ministry of Finance has
commented on whether non-taxable persons
are able to function as part of a VAT group.
In the current letter, it holds the opinion that
a non-taxable person cannot be a part of a
VAT group, but concedes that the inclusion
of non-taxable persons is allowed in principle
under Article 11 of Directive 2006/112/
EC due to the judgments of the Court of
Justice of the European Union dated on
9 April 2013 (C-85/11; commission/Ireland)
and on 25 April 2013 (C-480/10; commission/
Sweden). However, it does not hold the
opinion that it is mandatory to include non-
taxable persons into the regulations of a
VAT-group.
Concerning the exclusion of non-taxable
persons, the Federal Ministry of Finance
refers to Article 11 Paragraph 2 of
Directive 2006/112/EC, and explains that a
Member State implementing the regulations
regarding the VAT group is entitled to take
measures in order to prevent evasion as well as
avoidance of taxes by implementing this rule.
Concretely, the Federal Ministry of Finance
explains that the exclusion of non-taxable
persons prevents the abuse of increasing the
input tax deduction by including these persons
into the VAT group.
Nevertheless, the German Federal Ministry of
Finance has postponed its final opinion until
two decisions by the Court of Justice of the
European Union have been made. The cases
in question are C-108/14 – Larentia & Minerva
and C-109/14 – Marenave Schiffahrt referred
by the German Federal Finance Court to the
CJEU for a preliminary ruling. The questions
presented to the CJEU concern the calculation
method of the input tax deduction at a
holding company, as well as the inclusion of a
partnership in the VAT group. An outcome is
expected in mid 2015.
We also await the CJEU’s final judgment
in C-7/13 Skandia America, a case
referred by Sweden for preliminary ruling
regarding the interpretation of Article 11 of
Directive 2006/112/EC that asks if a branch (in
a Member State) can be part of a VAT group
independently from its head office (located
abroad).
Organisational links & the executive
employee
Until now, VAT grouping rules in Germany
have required a parent company to ensure by
organisational measures that it can prevent
a different decision-making process by the
subsidiary company (in terms of a daughter
company). Due to current jurisdiction by
the Federal German Finance Court, the
German Federal Ministry of Finance has now
dropped this opinion. To merely affirm an
organisational link between the subsidiary
and the parent company it is not sufficient to
prevent a different decision-making process. It
is actually necessary that the parent company
is able to assert its decisions within the
subsidiary company.
The organisational link terminates in cases
of bankruptcy if a liquidator was ordered in
favour of the company, and if the bankruptcy
court ordered that this decision will only
be valid upon approval of the (preliminary)
liquidator. For the time being, the Federal
Ministry of Finance reserves the release of
the judgment and its general application
beyond the individual case. For this purpose, it
refers to the requests for a preliminary ruling
(mentioned above).
Moreover, the Federal Ministry of Finance has
commented on the position of the executive
employee. So far, an executive employee
has been necessary to function as managing
director of the subsidiary company in the
context of the organizational link between
parent and subsidiary company. In future,
the leadership role is not mandatory any
more. In fact, in the opinion of the German
Federal Ministry of Finance not only executive
employees but rather all employees are
subject to a personal dependency due to the
employment contract between parent company
and employee. Therefore, the parent company
is entitled to dismiss its employee from the
position of managing director of the subsidiary
at any time in case of a decision contrary to
instructions given by the parent company, the
organisational link between parent company
and subsidiary is basically approved.
ANNETTE POGODDA-GRÜNWALD
DANIEL AUER
Germany – Berlin
annette.pogodda-gruenwald@bdo.de
daniel.auer@bdo.de

4. 4 INDIRECT TAX NEWS 2
GHANANEW VAT ACT INTRODUCED
V
alue Added Tax (VAT) is imposed in
Ghana under the VAT Act of 2013
(VAT Act). The VAT Act replaces the
1998 VAT law with effect from 1 January 2014,
but some of the provisions governing VAT
administration under the old law (including
those dealing with record keeping, recovery
of tax due, certain offences, penalties, and
appeals) continue to apply, pending enactment
of a comprehensive law governing the
administrative aspects of all domestic tax laws.
The VAT Regulations of 1998 also continue to
apply, subject to a few amendments.
VAT is charged on every taxable supply of
goods and services made in Ghana, on every
taxable importation of goods into Ghana, and
on the taxable supply of imported services.
The term “goods” is defined to include
movable and immovable tangible property,
thermal and electrical energy, heating, gas,
refrigeration, air conditioning, and water, but
excludes money. “Services” refers to anything
other than goods or money.
Under the VAT Act, a supply of goods or
services takes place and VAT becomes payable
as follows:
• When someone in Ghana acquires goods or
services for their own use: on the date on
which the goods or services are first used by
the person;
• When someone in Ghana acquires goods
or services by way of gift: on the date on
which ownership passes or the date the
performance of the services is completed;
• In any other case, on the earliest of the date
on which:
–– The goods are removed from the taxable
person’s premises, or from other premises
where the goods are under the taxable
person’s control;
–– The goods are made available to the
person to whom they are being supplied;
–– The services are supplied or rendered;
–– Payment is received; or
–– A tax invoice is issued.
At the end of each monthly accounting period,
a taxable person may deduct from the output
tax due for that period the input tax they paid
on goods and services purchased in Ghana
or on goods and services imported and used
wholly and exclusively in the course of their
business. The excess of input tax over output
tax may be carried forward for three months,
after which it is refunded.
No input tax deduction may be made in
respect of the following:
• The taxable supply or import of motor
vehicles or vehicle spare parts, unless the
taxable person is in the business of dealing
in, or hiring out, motor vehicles or selling
vehicle spare parts; or
• The taxable supply of goods or service in
respect of entertainment, including the
provision of restaurant meals, and hotel
expenses, unless the taxable person is in the
business of providing entertainment.
No input tax deduction is available to a
taxable person for purchases or imports of
exempt supplies.
On making a taxable supply of goods or
services, taxable persons must issue a
tax invoice in a format prescribed by the
Commissioner-General.
Every taxable person must submit a VAT return
not later than the last working day of the
month immediately following the accounting
period to which the return relates. The return
must show the amount of tax payable for the
period and the amount of input tax credit/
refund claimed.
ABEL MYBURGH
South Africa – Johannesburg
amyburgh@bdo.co.za
LATVIAVAT AMENDMENTS REGARDING
ELECTRONICALLY SUPPLIED SERVICES
T
he Latvian parliament (Saeima) is
currently working on amendments
to the VAT Law with respect to
electronically supplied services. The
amendments are needed to ensure compliance
with new place of supply rules, which will be
introduced throughout the European Union
with effect from 1 January 2015. The
amendments to Latvian VAT law are expected
to be in force from that date.
New rules
Under the amendments, the definition
of electronically supplied services will be
extended to be in line with the updated
Directive 2006/112/EK. Special regulations will
be introduced to determine the place of supply
of electronically supplied services provided
within the European Union to customers
that are not taxable persons. From 1 January
2015, regardless of where the taxable person
supplying the services is established, the place
of supply of such services shall be the Member
State where the customer is established, or
where the customer has his or her permanent
address, or where the customer usually
resides.
Furthermore, under a special regime,
known as the ‘Mini One Stop Shop’, if
electronically supplied services, radio and
television broadcasting services, or electronic
communication services are provided to a
recipient that is a non-taxable person, the
provider of the services will not be required
to register for VAT purposes in each Member
State where its customers are located. Instead,
the provider of such services will only have to
register in one Member State and submit VAT
returns there to account for VAT due on such
services in all other Member States.
To register for this special regime, the taxpayer
will be required to submit an application to
the Latvian State Revenue Service via the
electronic declaration system.
INITA SKRODERE
GITA AVOTINA
Latvia – Riga
inita.skrodere@bdotax.lv
gita.avotina@bdotax.lv

5. 5INDIRECT TAX NEWS 2
LUXEMBOURGVAT RATE INCREASES ON THE WAY
P
rime Minister Xavier Bettel recently
confirmed that Luxembourg VAT rates
will increase as of 1 January 2015. With
the exception of the super-reduced VAT rate
of 3%, which will remain unchanged, the
VAT rates of 6%, 12% and 15% will each be
increased by 2%.
The standard rate (currently 15% and
increasing to 17%) applies to most of
the supplies of goods and services. The
intermediary rate (currently 12% and
increasing to 14%) applies, for example, to
wine, commercial printing, and bank custody
services. The energy sector is subject to the
reduced rate (currently 6% and increasing
to 8%), whereas the supply of food, books,
and medication are taxed at the super reduced
rate (3%).
With this increase, the Luxembourg
government aims at partially offset the
EUR 800 million it expects to lose from the
implementation of the new place of supply
rules that will apply to electronic commerce
throughout the European Union with effect
from 1 January 2015.
ERWAN LOQUET
EMELINE COFFE
Luxembourg
erwan.loquet@bdo.lu
emeline.coffe@bdo.lu

6. 6 INDIRECT TAX NEWS 2
NETHERLANDSDUTCH AG ISSUES OPINION ON DEDUCTION OF VAT ON VACANT IMMOVABLE PROPERTY
U
nder Dutch VAT rules, entrepreneurs
are allowed to deduct VAT they paid
on costs incurred to purchase or
construct immovable property (buildings), to
the extent the purchased goods or services are
used for taxable activities for VAT purposes.
For investment goods, Dutch VAT law provides
for a “revision period”. During this period, the
use of the goods is monitored. For immovable
investment goods the revision period contains
the financial year in which the property
was taken into use for the first time and the
succeeding nine financial years. A change in
use (from taxable to exempt or from exempt
to taxable) during the revision period requires
a correction of the initial VAT treatment. If,
during the revision period, the portion of the
property that is used for a purpose that is
subject to VAT increases, as compared to the
portion used for the non-taxable purpose
in the year the property was put into use,
the entrepreneur can claim VAT it had not
deducted. On the other hand, if the use
changes and more of the property is used for
VAT exempted purposes, the entrepreneur
must repay the VAT it previously deducted.
In these difficult economic times, vacancy is a
regular occurrence in many properties. Since
the use of the immovable property during the
revision period is relevant for the deduction of
VAT, the question of how to deal with vacancy
during the revision period is common.
In case number 13/00282, which is pending
in the Highest Court in the Netherlands, the
Dutch Advocate General (AG) issued her
opinion on this issue. The case concerns an
immovable property that was initially used
for VAT exempt activities and so, when the
building was put into use, the owner had
no right to deduct input VAT. Subsequently,
however, when the property became vacant,
the owner hired a broker to find a tenant
that performs taxable activities for VAT
purposes, in order to opt for a taxable letting
for VAT purposes. According to the AG, in
this situation the owner had the intention of
using the property for VAT taxed activities,
so the taxpayer could claim part of the
initial non-deducted VAT based on the
revision rules. The AG was of the view that
the owner should be able to prove, based on
objective documentation, that it intended the
immovable property to be used for taxable
activities for VAT purposes during the vacancy
period.
According to the AG, in hiring the broker
and renting the property, the owner had the
intention of using the property for VAT-taxed
activities and so the AG was of the view that
1/10 of the initial VAT should be allocated to
each year of the revision period. However,
the AG was not entirely sure whether her
conclusion can be based on the EU VAT
Directive and case law of the European Court
of Justice. As a result, the AG advised the
Highest Court of the Netherlands to submit
preliminary questions to the ECJ.
Interestingly, the AG’s conclusion is not in line
with the present opinion of the Dutch State
Secretary of Finance. According to the State
Secretary, vacancy does not constitute the use
of the immovable property for taxable or non-
taxable activities. As a result, according to the
State Secretary, there should be no revision for
the period of vacancy. So, if VAT was deducted
in the first year the immovable property was
put into use, the initial deduction remains.
And, conversely, in situations where no VAT
has been deducted, the vacancy will not lead
to a recovery of VAT.
Treatment of VAT on maintenance and
other costs during vacancy
It is important to note that the opinions of
the AG and the State Secretary described
above deal with the deduction of VAT on costs
incurred to purchase or construct immovable
property. Other rules apply regarding the
deduction of VAT on maintenance costs and
other costs related to the immovable property
during vacancy. Based on the opinion of
the State Secretary, maintenance costs (for
example, energy and security costs) cannot be
directly allocated to a taxable activity, so the
VAT on such general costs is deductible on a
pro rata basis in the year of vacancy. The pro
rata basis is fixed as a percentage of taxable
turnover related to total turnover and is used
to determine the deductible proportion of VAT
on costs that are attributable to taxable and
non-taxable activities (general costs).
The VAT on other costs related to the
immovable property during vacancy (for
example, costs for improvement or expansion)
is deductible insofar as the entrepreneur
intends to allocate those costs to VAT-taxed
activities. The AG’s opinion does not relate to
the deduction of VAT on these costs.
If the Highest Court of the Netherlands
decides to submit preliminary questions to
the ECJ, the ECJ’s response will not be received
for some time. It is our opinion that it is
important to anticipate a potential positive
verdict, which means that if a taxpayer
intends to use the vacant property for taxed
activities, VAT will be deductible. As such, we
recommend taxpayers take care to record and
substantiate their intention regarding the use
of the property, for example, by entering into
a contract with a broker whereby the intention
is to find a tenant that meets the conditions
necessary to opt for a taxable letting for
VAT purposes.
MARCO BEERENS
JOOST VERMEULEN
The Netherlands – Breda
marco.beerens@bdo.nl
joost.vermeulen@bdo.nl

7. 7INDIRECT TAX NEWS 2
NEWZEALANDGST: CLAIMS BY NON-RESIDENT BUSINESSES & TOOLING COSTS
I
n a bid to remove Goods and Services Tax
(GST) as an impediment to non-resident
businesses doing business in New Zealand,
the government has created a new category of
“registered person” entitled “non-resident GST
business claimants”.
New Zealand’s GST is intended to be a tax on
consumption, rather than a tax on business. As
such, it is meant to be tax neutral until borne
by the final consumer. However, for non-
resident businesses, the non-recoverable GST
incurred on goods and services they receive
is a real cost – and one that is not borne by
New Zealand businesses, which can claim the
GST as an input tax credit. As a result, the GST
is not neutral – it creates a potential hurdle for
non-resident companies looking to trade with
New Zealand businesses.
Accordingly, new measures allow non-resident
businesses receiving goods and services in
New Zealand to register for GST and claim
GST refunds, if they meet the registration
criteria. The new provisions are effective from
1 April 2014.
Qualifying as a non-resident GST business
claimant
To qualify as a “non-resident GST business
claimant”, the following criteria must be met:
• The business must expect the GST refund
claim in its first GST taxable period to be
more than NZD 500, and
• In the country or territory of its residence:
–– The business must be a registered
taxpayer under a domestic consumption
tax, for example, a goods and services tax
or a value added tax, or
–– The business had a taxable activity with a
turnover of more than NZD 60,000 over
a 12-month period, but was not required
to be registered as a taxpayer under the
provisions of its domestic consumption
tax, or
–– The business has had a turnover of more
than NZD 60,000 over a 12-month
period and there is no domestic
consumption tax.
In addition, the non-resident business:
• Must not carry out, or intend to carry out, a
taxable activity in New Zealand and it must
not be a member of, or intend to become
a member of, a GST group carrying out a
taxable activity in New Zealand, and
• Must not be engaged in a taxable activity
that includes providing services where it is
reasonably foreseeable the services will be
received in New Zealand by someone who is
not registered for GST.
Registration
To register, a non-resident GST business
claimant must file IR564, the Non-resident
GST Business Claimant Registration Form, and
provide the supporting documents listed on
page 3 of the form, which are required as proof
of identity of the entity and its directors. The
documents required, which vary according to
the type of entity being registered, must be
scanned and sent to the New Zealand Inland
Revenue. Any non-resident businesses about
to register for GST should make sure they:
• Have the supporting documents they need
to go with their registration, and
• Get tax invoices and proof of payments
from their New Zealand suppliers for
business expenses relating to their GST
taxable activity. (Because a non-resident
can only register for periods on or after
1 April 2014, expenses and receipts
regarding transactions before 1 April 2014
cannot be claimed.)
The form, and details of the supporting
documents referred to in sections 8 and 17 of
IR564, can be downloaded from the Inland
Revenue website: www.ird.govt.nz. The
registration form, supporting documents
and first GST return may be emailed to:
54Bnonres@ird.govt.nz or posted to:
Non-resident Centre, Inland Revenue,
Private Bag 1932, Dunedin 9054,
New Zealand.
GST refunds to non-resident businesses will be
paid either into a New Zealand bank account,
if the non-resident business has one, or by way
of a New Zealand dollar cheque sent to the
postal address listed on the application.
GST on tooling costs
An amendment has also been made to the
NZ GST to allow a New Zealand resident
manufacturer of tools to zero rate the supply
of specialised tools supplied to non-GST
registered non-residents. Previously, where
such tools were manufactured under a
contract with a non-resident, the domestic
manufacturer was required to charge GST
at the standard rate of 15%, even when the
tools were used to make products that were
exclusively exported. This amendment also
takes effect from 1 April 2014.
IAIN CRAIG
New Zealand – Auckland
iain.craig@bdo.co.nz

8. 8 INDIRECT TAX NEWS 2
T
he European Court of Justice (ECJ) issued
a judgment in C-323/12 E.ON Global
Commodities SE (E.ON), on a matter
referred to it by the Appeal Court of Bucharest
concerning application of the 8th
Directive
(which has since been replaced by the EU VAT
Refund Scheme, covered by Directive 2008/9).
Background
E.ON, a company based in Germany,
delivered electric power in Romania. E.ON
hired Haarmann as its fiscal representative
in Romania, as required under Romanian
law before Romania became part of the EU.
Haarmann undertook activities on behalf of
E.ON that included re-invoicing of transport
services for which Haarmann issued invoices
on behalf of E.ON.
From 1 January to 31 August 2007 E.ON
deducted VAT of RON 5 118 071 it paid on
invoices issued by its commercial partners
(Romanian taxable persons acting as service
providers). On behalf of E.ON, Haarmann
submitted four VAT returns related to the
VAT amount paid by E.ON. After a partial tax
audit, Romanian tax authorities did not allow
the deduction because the tax authorities
were of the view that E.ON did not owe VAT
in Romania for the electric power deliveries
because the VAT obligation was transferred to
the beneficiary of the delivery. Based on the
tax audit report, a notice of assessment was
issued to recover the additional VAT the tax
authorities deemed E.ON owed.
E.ON contested the notice of assessment
and brought an action in the Appeal Court of
Bucharest. The court ordered that the notice
of assessment be cancelled and ordered the
tax authorities to refund the RON 5 118 071
to E.ON. The tax authorities appealed and the
High Court of Justice found in favour of the tax
authorities.
E.ON then requested reimbursement of the
VAT amount under the provisions of the
8th
Directive, which relates to harmonization
of the laws of Member States regarding
turnover taxes. The tax authorities argued that
reimbursement of VAT only applies to taxable
persons not registered who are not obliged to
register for VAT purposes in Romania. Since
E.ON had a fiscal representative (Haarmann),
E.ON was considered to be registered for VAT
purposes in Romania.
E.ON argued that the 8th
Directive provides
the conditions under which a taxable
person must be registered for VAT purposes
in Romania in order to benefit from
reimbursement of the paid VAT. The Appeal
Court suspended the matter and referred the
following preliminary questions to the Court
of Justice of the European Union (CJEU):
• If a taxpayer whose main headquarters is
in an EU Member State outside Romania
is registered for VAT purposes in Romania
through a fiscal representative under
Romanian laws that were applicable before
Romania joined the EU, may the taxpayer
be considered to not be established in
Romania for purposes of application of the
8th
Directive provisions?
• If the requirement under Romanian law
that a taxpayer not be registered for VAT
is a supplementary condition to the ones
expressly regulated by the 8th
Directive, is
such a supplementary condition permitted?
• If the requirements of the 8th
Directive
can mandate the fulfilment of express
conditions required to establish entitlement
to a VAT reimbursement to taxpayers not
established in Romania, is this so regardless
of the provisions of national legislation?
The CJEU decided that E.ON was entitled the
claim a refund of VAT under the 8th
Directive.
It concluded that the provisions of the
8th
Council Directive 79/1072/EEC must be
interpreted as meaning that a taxable person
established in one Member State who has
made supplies of electricity to taxable dealers
established in another Member State has the
right to rely on the 8th
Directive to obtain
a refund of input VAT it paid in the other
Member State. According to the CJEU, that
right is not precluded merely because the non-
resident designated a tax representative for
VAT purposes in the latter state.
DAN BARASCU
HORIA MATEI
Romania – Bucharest
dan.barascu@bdo.ro
horia.matei@bdo.ro
ROMANIAEU VAT REFUNDS: APPLICATION OF FORMER 8TH DIRECTIVE TO NON-RESIDENT WITH ROMANIAN TAX REPRESENTATIVE

9. 9INDIRECT TAX NEWS 2
S
ingapore has established itself as a
thriving financial centre of international
repute. Singapore‘s financial centre
offers a broad range of financial services
including banking, insurance and fund
management, and administration.
To further strengthen Singapore’s position
as a centre for fund management and
administration, the Monetary Authority of
Singapore (MAS) issued a circular that extends
the GST remission on expenses for qualifying
funds managed by prescribed fund managers
to 31 March 2019. In the circular, the MAS
also provided updates on how to determine
whether a fund is considered to “belong” in
Singapore for GST purposes.
How the updates affect the fund
management industry
GST remission for funds
Normally, 7% GST is chargeable on fund
management, custodian, and other services
supplied by GST-registered suppliers to
“funds belonging in Singapore”. Only GST-
registered funds making taxable supplies
are able to claim the GST incurred on their
expenses. As some of the funds are not
eligible for GST registration because of the
type of investment activities they make,
the GST incurred on the fees charged is an
unrecoverable business cost to these funds.
A GST remission was introduced on
22 January 2009 to allow qualifying funds that
are managed by a prescribed fund manager
in Singapore to claim GST incurred on all
expenses related to the fund’s investment
activities (other than specifically disallowed
expenses) at an annual recovery fixed rate
determined by the MAS. The remission was
originally provided for expenses incurred from
22 January 2009 to 31 March 2014 inclusive.
In the 2014 Singapore Budget Statement, it
was announced that the GST remission would
be extended to 31 March 2019. The circular
confirms and provides the details about the
extension.
To qualify for the GST remission, the following
conditions must be met:
• The fund must satisfy conditions for
income tax concessions in Singapore as
a Section 13C, 13G, 13R, 13X fund, 13CA
fund (with effect from 1 January 2014), or
it must be a designated unit trust or a unit
trust included under the CPF Investment
Scheme (CPFIS) as at the last day of its
preceding financial year.
• The fund must be managed or advised by
a prescribed fund manager in Singapore.
(Prescribed fund managers are those that
hold a capital markets licence under the
Securities and Futures Act (Cap. 289) for
fund management and those that are
exempt under the Securities Futures Act
from holding such a licence).
In the circular, the MAS set the fixed recovery
rate for 1 January 2014 to 31 December 2014
at 90%. Funds that meet the qualifying
conditions are required to file a quarterly
statement of claims to make the claims based
on their financial year end. This allows funds
that are not eligible for GST registration to
mitigate the GST incurred while doing business
in Singapore.
Determination of “belonging” status of a
fund
Under the GST legislation, zero-rating (GST
at 0%) generally applies to services (for
example, fund management services) that
are supplied under a contract with, and for
the direct benefit of, persons that “belong” in
a country other than Singapore at the time
the services are performed. The 7% GST is
applicable on services (for example, fund
management or custodian services) supplied
to funds belonging in Singapore.
In the circular, the MAS clarified how you
determine whether a fund (other than trust
fund) is treated as “belonging in Singapore”.
According to the MAS, a fund is considered to
be “belonging in Singapore” if:
• The fund has an administration office with
employees in Singapore;
• The fund does not have any employees
or an administration office of its own in
any country and the fund relies solely
on a Singapore fund manager to carry
on its business activities (in other words,
a Singapore fund manager has overall
responsibility to oversee and carry out the
activities of the fund and that manager is
the sole contracting fund manager for the
fund);
• The fund does not conduct board meetings
at a fixed location outside Singapore on a
permanent basis.
The rules for determining that a fund belongs
in Singapore took effect from 1 April 2014.
With the updates to the rules, certain
services (for example, fund management
services) supplied to offshore funds that were
incorporated outside Singapore (which used to
be subject to 0% GST before the updates) may
now have to be standard-rated and charged
with 7% GST.
Where the fund qualifies for the GST
remission, it is possible to mitigate the GST
costs as the fund will be able to recover a
percentage of the GST (based on the annual
recovery fixed rate) that was charged by the
service providers.
How BDO Singapore can assist
Given the updates to the GST rules, service
providers and fund managers should review
the “belonging” status of funds that were
incorporated outside Singapore (especially if
the fund has fund managers in Singapore that
have discretionary authority to act for the
fund). Penalties will apply for incorrect returns
filed and for any late payment made to the
Inland Revenue Authority of Singapore (IRAS).
The updates to the GST rules are also
important considerations for offshore funds
that intend to engage Singapore service
providers (for example, a Singapore fund
manager) and for incorporating a new fund in
Singapore.
BDO Singapore can help service providers
review the GST treatment on the fees they
charge to offshore funds to ensure that
the GST treatment is correctly applied and
also to advise offshore funds on the GST
requirements in Singapore.
In addition, BDO Singapore can help assess
whether a fund is eligible for the GST
remission and, if so, we can help the fund
with their filing of the quarterly statements of
claims.
EU CHIN SIEN
YVONNE CHUA
Singapore
chinsien@bdo.com.sg
yvonnechua@bdo.com.sg
SINGAPOREGOODS AND SERVICES TAX (GST) UPDATES FOR THE FUND MANAGEMENT INDUSTRY

10. 10 INDIRECT TAX NEWS 2
SPAINVAT – DIRECTORATE GENERAL OF
TAXATION TAX RULING Nº V0445-14
SWITZERLANDSWISS SUPREME COURT SAYS U.S. DATING WEBSITE OPERATOR MUST
REGISTER FOR VAT
A
taxpayer that had been providing
zero rated VAT services to its
customers requested a ruling when,
after a tax inspection, the Spanish Tax
Authorities determined that the taxpayer
should have been charging VAT on the
transactions in question.
The Spanish VAT Act provides that if a VAT
taxpayer has miscalculated the amount of VAT
they should have charged, they must reissue
the invoice showing the correct amount of VAT
owing.
Corrections to the invoice must be made at
the time the miscalculations are detected,
provided that the period between the date the
tax accrued and the date on which the error is
detected does not exceed four years. This rule
also applies when an invoice is issued without
the appropriate VAT charged.
The new wording of the Spanish VAT Act
(effective from 2014 onwards) provides that
a taxpayer cannot re-issue invoices with the
correct VAT chargeable if:
1. If the Spanish Tax Authorities determine
that the taxpayer incorrectly omitted
charging VAT, and
2. If the Spanish Tax Authorities can prove that
the taxpayer failed to charge VAT by reason
of fraud.
Previously, if the tax authorities found that
failure to charge VAT lead the Spanish Tax
Authorities to impose a tax penalty, the
taxpayer was not permitted to re-issue the
relevant invoice with the correct VAT.
With respect to the right of the party invoiced
to offset VAT paid against its output VAT, the
Spanish VAT Act allows parties liable to the tax
to adjust setoffs when the amount of VAT they
were charged has been miscalculated or when
they receive amended invoices from suppliers.
When a taxpayer receives a corrected invoice
that results in an increase in any VAT the
taxpayer initially set off, the taxpayer may
make appropriate adjustments in its VAT tax
return corresponding to the period in which
the taxpayer either receives documentary
proof of the correct amount of VAT owing or in
a subsequent VAT return, so long as the period
between the date the VAT accrued and the
date on which the error is corrected does not
exceed four years.
DAVID SARDÁ
ALEX SOLER
Spain – Barcelona
david.sarda@bdo.es
alex.soler@bdo.es
O
ne of the unique things about VAT is
that is can apply across international
borders, especially when services are
provided to Swiss residents via the internet.
As a general rule, when someone in
Switzerland acquires services from abroad
and the services provided in a single year are
valued at more than CHF 10,000, the Swiss
resident must inform the Swiss tax authorities
and pay 8% Swiss VAT on the value of the
services acquired.
Of course, most rules have exceptions, and the
Swiss Supreme Court recently considered an
exception that requires a foreign provider to
register as a Swiss VAT taxpayer with regard
to certain IT services, rather than have the
Swiss final customer declare the Swiss VAT on
acquisition of the service.
The Supreme Court concluded in the case
(ATF-2C-1100/2012) that a U.S. online
dating website that had some Swiss-resident
customers had to register as a Swiss VAT
taxpayer.
The Court held that Swiss VAT registration is
compulsory for a foreign company managing
an online dating website from abroad if the
website has Swiss resident customers.
In reaching its decision, the Court concluded
that an online dating website is considered to
provide IT service, based on the following:
1. The information is provided electronically
2. The technology used (the internet) is not a
just a means of transmission; and
3. The service cannot be provided without that
technology.
This case, in effect, demonstrates that with
regard to VAT, the fundamental question is
always multi-faceted: “Who does what and
where?”.
ALEXANDRE SADIK
PAOLA GARIERI
Switzerland – Geneva
alexandre.sadik@bdo.ch
paola.garieri@bdo.ch

11. 11INDIRECT TAX NEWS 2
UNITEDKINGDOMREPORT ON THE WORLD CUSTOMS ORGANISATION’S AUTHORISED ECONOMIC OPERATOR CONFERENCE
T
o improve supply chain safety and
security, the European Commission
introduced Authorised Economic
Operator (AEO) status in 2008. Conferring
AEO status on qualifying businesses is part of
an internationally coordinated approach aimed
at combating terrorism and non-compliance in
global trade.
Businesses that are engaged in sourcing
products for their supply chain from around
the globe can apply to their domestic
customs authority for AEO status. Such status
demonstrates that the holder is a “trusted
trader” for customs purposes and provides
certain assurances as to the safety and
security of the AEO’s supply chain.
The World Customs Organisation held its
second Global AEO conference in Madrid in
late April 2014. Delegates at the conference
included individuals from industry, practice,
academia, and public policy. Among the topics
discussed were: the growing importance
of AEO status in international trade, the
benefits of AEO programs in terms of trade
facilitation, the development and progress of
Mutual Recognition Agreements (MRAs), and
the increasing emphasis on engagement with
Small and Medium Sized Enterprises (SMEs).
Growing importance of AEO status
At the conference, representatives from
several key organisations, including the
European Commission, U.S. Customs
and Border Protection, the Organisation
for Economic Cooperation and
Development (OECD), and the World Trade
Organisation (WTO) all emphasised the
growing importance of AEO programs in
encouraging international trade.
The representatives of these organisations see
AEO programs as a tool for achieving the key
objectives of:
• Reducing the general administrative burden
involved in trading internationally,
• Improving security in the supply chain, and
• Helping to speed up the clearance of goods
at port.
Benefits in terms of trade facilitation
Efforts are being undertaken around the world
that are aimed at unlocking the potential
of international trade in order to improve
global economic outlook; such efforts include
bilateral trade agreements (such as the
proposed Trans-Atlantic Trade and Investment
Partnership (TTIP) between the U.S. and
the EU), and multilateral trade deals (such
as the recent Bali agreement negotiated by
the WTO).
Policymakers and businesses see AEO
programs as a device that will help deliver
capacity building and create an environment
within which international trade can flourish.
AEO status can facilitate faster clearance
at port (through fewer interventions by
customs officials and the creation of special
AEO “lanes” for trusted traders) and can
increase confidence in the safety and security
of strategic suppliers (through the creation of a
globally recognised and regulated standard).
Progress of MRAs
Authorised traders under an AEO program
can also take advantage of faster customs
clearance and reduced physical and
documentary controls when importing or
exporting into countries that participate in
MRAs. Currently there are around 25 active
MRAs and it is expected that the number
of MRAs in operation around the world will
increase significantly over the next few years.
This will substantially increase the benefits of
AEO authorisation.
Engagement with SMEs
The other important theme emphasised
at the conference was the applicability of
AEO programs to SMEs. For a long time there
was a perception that AEO programs were
intended primarily for the largest corporates.
A number of case studies discussed at the
conference involving SMEs made it clear
that successful application for AEO status is
advantageous to businesses of any size.
ONELIA ANGELOSANTO
JONATHAN P STACEY
United Kingdom – Manchester
onelia.angelosanto@bdo.co.uk
jonathan.stacey@bdo.co.uk

12. 12 INDIRECT TAX NEWS 2
UNITED STATESSALES TAX SYSTEMS IN THE USA – AN OVERVIEW
T
he United States does not have a value
added tax at either the federal or the
state level. Sales and use taxation in
the United States is operated independently
by each of the 50 states. Sales taxes are
administered by every state except Alaska,
Delaware, Montana, New Hampshire and
Oregon. Although in these five states a state-
imposed general transaction tax is not present,
localities may tax transactions or there may be
a state-imposed tax on specific items (e.g. gas,
car rentals, alcohol). The sales tax rates vary
from 2.9% to over 10%.
Sales tax is usually the responsibility of the
trader to charge and remand to the state, and
stated separately (or implicitly added at the
time of sale) to consumers. Unlike a value
added tax, a sales tax is imposed only once at
the retail or consumer level.
Purchases in the United States
US companies are responsible for collecting
tax on sales to their customers. Out-of-state
traders often fail to tax an item shipped
into a neighbouring state when their own
state‘s guidance does not require taxation.
In these situations use tax is often due but
remains unpaid by the purchaser located in
the state of delivery. Tax auditors often count
on inadequacy in sales tax reporting of this
type and assess tax, interest and penalties on
often unsuspecting taxpayers. In most states
an auditor may review and assess use tax on
transactions of this type going for up to four
years back.
Internet sales in the United States
Contrary to popular belief, internet
transactions are not exempt in any US states.
However, a seller who does not have nexus
in a particular state is not liable for collection
of sales tax in that state. The purchaser is
liable to remit use tax voluntarily on these
purchases. In many states tax is due from the
purchaser in the jurisdiction where possession
of an item is taken, while in other states the
location of ‘first use’ or some other factor may
determine where tax is due.
Taxation of services in the United States
In most states professional services such as
those provided by doctors and lawyers are
not subject to sales tax; however, taxation of
non-professional services or general labour
vary widely from state to state. Given this
fact, a thorough examination of a company’s
service provisions (and purchases) should
be considered before beginning business
operations in a state and should be regularly
reviewed throughout the course of a business’s
ongoing operations.
Taxation of manufacturing in the
United States
Taxation of manufacturing institutions
varies widely from state to state. States such
as Texas, Florida and New Jersey provide
liberal but often complex exemption rules
that are continually contested under audit.
California, on the other hand, is one of the
least liberal states concerning manufacturing
operations. Some states, such as Colorado,
provide enterprise-zone exemptions that
expand further on manufacturing (and
other) exemptions. In Colorado, for example,
the state’s manufacturing exemptions are
extended in some regions to cover mining
operations for gas, oil and other minerals.
Regardless of the state in which manufacturing
or mining is performed, a thorough review of a
state’s guidance is critical.
Taxation of software in the United States
One of the most complex sales and use
tax areas is the taxation of software. Most
companies do not sell software but spend
significantly on software and software
licensing. The following primary issues should
be considered when purchasing (or selling)
software or licensing:
• Custom-designed software vs ‘canned’ (pre-
written) software
• Software delivery method
• Central (i.e. web-based) vs local installation
• Software maintenance (i.e. regular
upgrades).
Sales tax return filing requirements
Sellers of taxable property must file tax
returns with each jurisdiction in which they
are required to collect sales tax. The most
common sales and use tax return filing
frequencies are monthly, quarterly and
annually. The tax return filing frequency
determination will vary between the states,
but a filing frequency status is usually based
on the taxpayer’s gross sales volume and
tax amount due. Each state requires their
own official sales and use tax form to be
completed.
Sales tax returns typically report all sales,
taxable sales, sales by category of exemption,
and the amount of tax due. Where multiple
tax rates are imposed (such as on different
classes of property sold), these amounts are
typically reported for each rate. Some states
combine returns for state and local sales taxes,
but many local jurisdictions require separate
reporting. Some jurisdictions permit or require
electronic filing of returns. Some states
provide a discount to vendors upon payment
of collected tax.
Sales tax return due dates varies among the
states. Each has a specific due date for their
tax returns and payments are typically due on
the 10th, 15th, 20th or at month end. Most
states will only grant extensions for filing sales
tax returns for a good cause such as natural
disasters. Lack of funds usually does not
constitute a good cause. Every state imposes
a stiff penalty and interest charges for the late
filing and payment of sales and use tax returns.
Sales taxes collected in some states are
considered to be money owned by the state,
and consider a vendor failing to remit the tax
as in breach of its fiduciary duties.
Sales for resale
Most states sales and use tax laws require
sales or use tax to be collected on the sales of
taxable tangible personal property or services
unless the property was purchased to be
resold. For example, goods purchased to be
incorporated into in the finished product are
generally not taxable. Steel purchased to be
part of machines is generally not taxable. Also,
the purchase of property to be subsequently
rented in the same form as acquired may also
be purchased for resale. However, supplies
consumed and not incorporated into the
manufactured product for sale may be taxable.
Criteria vary widely by state.

13. 13INDIRECT TAX NEWS 2
Exemption certificates
Generally purchasers are required to pay sales
tax unless they are an exempt entity or they
will use the property purchased in an exempt
manner. Many state and local governments
have extended a sales tax exemption to
certain purchasers. These purchasers include
but are not limited to federal governments,
state and local governments, charitable
organisation, non-profit corporations and
companies that are located in tax free
“enterprise zones”. Many states allow for the
purchase of materials, tooling and equipment
that will be used a qualifying manufacturing
or research and development operations to be
exempt from sales or use tax.
All states require the seller to collect sales tax
from the purchaser unless the seller receives
either a resale certificate or an exemption
certificate from the purchaser. The seller
cannot blindly accept the resale or exemption
certificate from the buyer. The seller must
know enough about their customer and
understand the nature of the purchasers
business in order to be able to accept the
certificate in good faith.
The format of the resale or exemption
certificate varies from state to state. It
is important to understand each state’s
certificate requirements relating to the
minimum amount of content and information
required on a certificate. Some states
certificates never expire while other states
require their certificates to be renewed
annually. Some certificates may qualify as
blanket certificates covering all transactions
purchased from a buyer while other
certificates may only cover a single purchase.
All certificates should be stored in a safe place
and never discarded.
Tax audits
All states imposing sales taxes examine sales
and use tax returns of many taxpayers each
year. The audit will cover the periods open
under state’s specific statute limitation rules.
The typical periods open under a state’s
sales and use tax audit is 3-4 years. Under
many states rules, the statute of limitations
never expire if a taxpayer has filed false or
fraudulent returns. Upon such audit, the
state may propose adjustment of the amount
of tax due. Taxpayers have certain rights of
appeal, which vary by jurisdiction. Some states
require payment of tax prior to judicial appeal,
and some states consider payment of tax an
admission of the tax liability.
STEVE OLDROYD
United States – San Francisco
soldroyd@bdo.com

14. 14 INDIRECT TAX NEWS 2
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, July 2014. 1406-04
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
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 20 June 2014.
Currency unit
Value in euros
(EUR)
Value inUS dollars
(USD)
South African Rand (ZAR) 0.06877 0.09360
Euro (EUR) 1.00000 1.36084
New Zealand Dollar (NZD) 0.64058 0.87179
Swiss Franc (CHF) 0.82142 1.11784