David Hardesty's
ecommercetax.com site this week carries an article on the trend
towards globalisation of tax as a consequence of the globalisation
of e-commerce. If remote selling via the Internet becomes a major
part of world trade, asks Hardesty, does it not follow that sales
tax and VAT collection systems will also have to adopt a much
more international model? Hardesty begins from the Ottawa conference
in 1998 that set out OECD goals for harmonising world-wide taxation
as:
Prevent tax evasion,
Close interstate and inter-country loopholes,
Decrease tax competition,
Ease the tax compliance burden of remote sellers,
Protect remote sellers from double taxation, and
Protect local retailers from remote sellers who use the tax laws
to gain an unfair competitive advantage.
The article reviews
progress on meeting these goals, particularly noting the OECD's
TAG (Technical Action Group) on the characterisation of income:
countries with a net surplus on e-commerce trade prefer income
to be taxable as trading profits because they tend not to have
taxable permanent establishments in foreign countries, while countries
with an e-commerce deficit prefer the income to be characterised
as royalties, becuase they have withholding taxes on royalty payments.
Professor Hardesty
notes the OECD campaign against 'offshore', concluding rather
challengingly that: 'The OECD seems determined to make tax havens
pariah states. It seems unlikely substantial enterprises will
wish to do business there. The business of these remaining havens
may be limited to criminals and those that are pathologically
anti-tax.' Ask Bermuda what it thinks of this!
Finally, addressing
the question of whether there will ever be a harmonised global
tax system, David Hardesty thinks that firms selling into dozens
of remote jurisdictions won't tolerate having to cope with multiple
VAT regimes, and that a unified regime may develop:
'Some have suggested
a single registration point for worldwide VAT collection. A company
would register with one organization, which would collect the
tax, and would remit the tax to various countries, based on the
location of sales. Obviously, such a system would require a fair
degree of consistency among the VAT systems of countries around
the world. Does this not look like a one-world tax system?'
See the complete
article at: http://ecommercetax.com/doc/112600a.htm