Around the world with VAT and GST on digital EY Global Indirect Tax Symposium 2016

Transcription

1 Around the world with VAT and GST on digital EY Global Indirect Tax Symposium April 2016

2 Panel Brad Miller Australia Folkert Gaarlandt South Africa Gino Dossche Puerto Rico Jennifer O Sullivan Qatar Page 2

3 Agenda Panel discussion Snapshot of global changes Puerto Rico Middle East and GCC Africa Australia and New Zealand Breakout to country tables Page 3

4 Global indirect tax changes impacting digital snapshot view New VAT/GST regime Change for e-services or similar Canada consulting on potential GST obligations for foreign e-commerce businesses Chicago 9% tax on streaming services from 1 September 2015 and certain cloud computing services from 1 January 2016 USA various pieces of draft federal legislation that would impose a SUT collection requirement for out-of-state suppliers Costa Rica awaiting legislative approval for planned introduction of VAT at 13% in 2016, rising to 15% in 2017 Bahamas introduced VAT 1 January 2015 Puerto Rico SUT rate increases to 10.5% from 1 July 2015; introduction of VAT postponed from 1 April 2016 OECD Discussion Draft on international guidelines for the taxation of B2C digital supplies This information has been prepared for general information purposes only and is not intended to be relied upon as advice. Please refer to your usual EY advisor for specific advice. Switzerland under the proposed changes (delayed until January 2017), the CHF100,000 VAT registration threshold for any business (including foreign suppliers of e-services) making supplies in Switzerland will be based on worldwide turnover. Foreign online retailers of goods will also become liable for Swiss VAT if their sales/deliveries to Swiss customers exceeds CHF100,000. Suriname proposal to replace current turnover tax from 1 January 2016 has been postponed EU 1 January 2015 VAT changes; European Commission digital single market strategy paper issued in May 2015 Italy considering introducing virtual PE rules and WHT for digital services. Digital newspapers and magazines will now qualify for the 4% VAT rate already applicable to e-books. Algeria VAT rate increased from 7% to 17% on mobile internet services Egypt moving from general sales tax to VAT in January 2017 South Africa foreign suppliers of electronic services required to register if supplied to South African resident or payment is received from South African bank account (1 June 2014); no specific rule for telecommunication services. Considering extending to supplies of software Czech Republic 1 April 2015 extension of domestic reverse charge to include mobile phones and laptops Israel proposing to charge VAT on online advertising (date TBC) Tanzania new VAT Act took effect on 1 July 2015; foreign vendors of B2C telecommunications and e-services over c. 10,000 required to register for VAT Turkey potential VAT charge on sales of advertising services to Turkish customers) Ghana Ghanaian VAT registration threshold will apply to nonresident providers of B2C e-services. India moving from CST/service tax to VAT (originally implementation date: 1 April 2016; now delayed) Russia planning to apply VAT to e- services provided by overseas companies to Russian customers 1 January 2017 GCC discussing introducing VAT (date TBC ) China moving from business tax to VAT in May 2016 Japan from 1 October 2015, sales of B2C (defined by nature of service, not customer) online content by nonestablished suppliers will be subject to Japanese VAT South Korea sales of mobile applications made by vendors located outside of South Korea will be subject to South Korean VAT (B2B and B2C) from 1 July Currently considering proposal to remove the requirement for B2B supplies. Malaysia introduced GST 1 April 2015 Australia consulting on potential GST registration for overseas digital suppliers (date proposed:1 July 2017) New Zealand GST registration for overseas digital suppliers 1 October Page 4

5 Global indirect tax changes impacting digital timeline view Malaysia GST implementation Czech Republic extension of domestic reverse charge to include mobile phones and laptops Tanzania new VAT Act takes effect; foreign vendors of B2C telecoms and e-services over c. 10,000 are required to register for VAT; VAT rate at 18%. South Korea foreign vendors of B2B and B2C e-services are required to register for VAT; VAT rate at 10%. Proposal to remove B2B supplies from scope is currently under consideration. Chicago 9% tax on various types of e-services (both B2C and B2B affected). Japan digital services are taxed according to customer s location. Foreign vendors need to register for VAT for B2C e-services, while B2B e- services are subject to reverse charge. Algeria VAT rate will be increased from 7% to 17% for mobile internet services. Puerto Rico intended introduction of VAT. India proposed GST implementation (now potentially subject to delay). New Zealand GST to apply to cross-border supply of services to New Zealand from 1 October Switzerland under the proposed changes (delayed until January 2017), the CHF100,000 VAT registration threshold for any business (including foreign suppliers of e- services) making supplies in Switzerland will be based on worldwide turnover. Foreign online retailers of goods will also become liable for Swiss VAT if their sales/deliveries to Swiss customers exceeds CHF100,000. Australia if proposed measures adopted, foreign vendor will need to register for VAT for B2C e-services. GCC discussing introducing VAT (date TBC ). Russia planning to apply VAT to e- services provided by overseas companies to Russian customers 1 January April May June July August September October January April October January April Q15 Q3 Q China start of VAT pilot for real estate and construction China start of VAT pilot for lifestyle services Q4 2015/Q China start of VAT pilot for financial services VAT/GST compliance footprint VAT/GST processes Systems architecture and functionality Issues to consider Records and audit readiness Arrangements with intermediaries Contracts Pricing and margins Customer experience Commercial strategy within certain markets Page 5

6 Global indirect tax changes impacting digital summary of upcoming changes Upcoming introduction of VAT and GST regimes (dates not yet confirmed) Egypt Expected that the implementation will be announced and effective within this year. If implementation goes ahead, foreign vendors of B2C broadcasting and e-services may have a VAT registration requirement. GCC (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and the UAE) Draft VAT framework agreed in May 2015; publication expected in late Six separate VAT regimes governed by common principles; simultaneous implementation in mid-late 2017 (now potentially delayed). Costa Rica Awaiting legislative approval for planned introduction of VAT at 13% in 2016, rising to 15% in 2017 Potential introduction of local VAT and GST registration for foreign vendors of e-services (dates not specified) Israel potential 17% rate VAT on B2B and B2C sales of digital advertising services to Israeli customers. Turkey potential VAT charge on sales of advertising services to Turkish customers. Italy considering introduction of virtual PE rules, whereby a 25% withholding tax charge is made on payments to foreign vendors of digital services. Canada consultation document issued in June USA various pieces of federal legislation that would impose a SUT collection requirement for out-of-state sellers are currently in draft. Ghana VAT registration threshold will apply to non-resident providers of B2C e-services. Other updates OECD BEPS focus on taxation of the digital economy European Commission digital single market strategy paper issued in May 2015 Algeria - VAT rate was increased from 7% to 17% on mobile internet services October 2015 Russia planning to apply VAT to e-services provided by overseas companies to Russian customers from 1 January 2017 South Africa will extend the scope of e-services to include software products; foreign vendor of B2B and B2C sales will need to register for VAT Issues to consider: VAT/GST compliance footprint VAT/GST processes Systems architecture and functionality Records and audit readiness Arrangements with intermediaries Contracts Pricing and margins Customer experience Commercial strategy within certain markets Page 6

7 European Union latest announcement on digital On 7 April 2016, the European Commission adopted its Action Plan on VAT to move toward a more coordinated single European Union (EU) VAT area. The Action Plan has a digital strategy that proposes to introduce legislation by the end of 2016 to modernize and simplify VAT for cross-border e-commerce by: Extending the current one-stop shop concept to all cross-border e-commerce, including distance sales Introducing common EU-wide simplifications measures to help small start-up e-commerce businesses Streamlining audits in this sector (home country audits) Removing the VAT exemption for the importation of small consignments from suppliers in third countries Page 7

8 Puerto Rico Gino Dossche Page 8

9 Puerto Rico background Puerto Rico (PR) has a budgetary deficit problem, leading to the introduction of VAT Hybrid SUT-VAT system introduced in 2013 Transactions from 1 June 2016 will be subject to a VAT of 10.5% or 0% 1% municipal SUT will apply in addition to VAT, except for B2B and designated professional services The Puerto Rico Treasury Department (PRTD) estimates that the change from SUT to VAT will increase the tax revenue from US$1.2b to US$2.7b after it is fully implemented Page 9

10 Puerto Rico VAT rules PR VAT follows general concepts: Collected at every stage of the supply chain Tax charged on sales (output VAT) Tax paid on purchases (input VAT) In general, VAT system allows registered merchants to take a credit on the VAT paid on their inputs Business customers will need to ask their taxable suppliers to issue VAT invoices or risk losing input VAT recovery As a general rule, registered merchants should act as withholding agents, but the buyer may also be liable in case of non compliance Normal self-assessment rules for imported services Page 10

11 Puerto Rico Anomalies (atypical VAT rules similar to existing SUT rules) Very broad nexus rules that may require registration for VAT, even without local physical presence: Mail order sales Owning property (real or personal) in PR Using third parties to solicit business in PR; click-thru nexus Numerous exemptions, some of them are based on the status of the customer and not the transaction: Typical exemptions financial services, insurance and health care Specific exemptions sales of vehicles, fuel and granting of rights to use intangibles Customer-based exemptions sales to the Government, hospitals and hotels Page 11

12 Puerto Rico digital economy Providing electronic services to PR resident may trigger VAT registration The supply of intangible assets is an exempt transaction in PR Mail order merchants have to register for VAT in PR and charge VAT on each taxable transaction Page 12

13 Middle East and GCC Jennifer O Sullivan Page 13

14 Jordan Overview The General Sales Tax (GST) Law was introduced in June 1994 (amended) and provides for two types of taxes: the general tax (GT) and special tax (ST). ST is part of the tax base for GT if ST applies. The Jordanian GST law adopts the United Nation s ISIC3 for services identification and Custom Harmonize Tariff system for goods categorization and identification. General Sales Tax (GST) applies to the following transactions: The supply of taxable goods or services made by a taxable person The importation of taxable goods or services ST rates vary (20 types of goods and 1 type of service are subject to percentage rates or fixed amounts set forth in Regulation No. 80 of 2000) ST return periods GT rates Standard Reduced Other GT return periods Monthly 16% 4%, 8% Zero-rated and exempt Two months Imports Imported goods Importers of goods must pay the tax due on the goods as the clearance stage to the Customs Department in accordance with the procedures applicable for the payment of customs duties. Clearance of these goods is not finalized until the tax due is paid in full. Imported services Importers of services must pay the tax due at the earliest of the following dates: Within one month after the date of payment for the imported service or after the date of making a partial payment, limited to the amount paid When the means that include the services (for example, compact disks and tapes) asam3 released from customs Within six months after the date on which the service or any part of the service is received, limited to the amount related to the part received Annual thresholds Goods (trade) Services Manufacturing Manufacturing (ST applied) Imports of goods or services for non personal purposes Imports of goods or services for personal purposes Recovery of GST by nonresident business AM4 JOD75,000 JOD30,000 JOD50,000 JOD10,000 Recovery of GST by taxable persons Zero None No A taxable person may recover input tax, which is GT charged on goods and services supplied to it, for business purposes. Input tax is generally recovered by being deducted from output tax, which is GST charged on supplies made. Page 14

15 Slide 14 AM3 AM4 Should "as" be "are"? Alan Millar, 29/04/2016 Spacing looks odd. Alan Millar, 29/04/2016

16 Egypt move from GST to VAT Sales taxes in Egypt: VAT Sales tax in Egypt is imposed on all manufactured goods, except for those goods exempted by special articles in the GST Law at a rate of 10%. Special rules for rates, exports, etc. The Egyptian Government is in the process of introducing a full VAT system to replace the current sales tax law: it is expected that it will be announced and effective within this year. Main features of VAT in Egypt: Full potential for deductibility of input tax for service companies Registration threshold - EGP500,000 Companies will have the right to refund taxes. The VAT tax rate will be within the range of 10% to 14%. There will be a reverse-charge mechanism. Page 15

17 Lebanon VAT Law Taxpayer (Article 3 of the VAT Law) Individuals and entities performing taxable or exempted supplies with the right of deduction (goods or services). Achieving a total turnover of LBP150 million in the last four quarters No threshold for optional registration. Taxpayer can be an individual, entity or a group VAT rate: In Lebanon, the two rates of VAT are the standard rate of 10% and the zero rate (0%). Exempt treatment is also present. VAT returns: Quarterly electronic filing now mandatory. Page 16

18 The GCC VAT There is currently no VAT or GST in the GCC. However, it is anticipated that: The GCC VAT framework will be finalized and formally announced by mid Businesses will be given at least 18-month lead time to become compliant from the date of announcement of the GCC VAT framework. Most GCC countries will be working to implement VAT by 1 January 2018 to avoid distortions arising from intra-gcc trade. All GCC states will need to have implemented VAT by the end of Page 17

19 The GCC VAT The GCC VAT Framework Agreement: Overarching legislation, allows for derogations Each GCC member state will transpose its provisions into their own domestic VAT law EU-type VAT model, as GCC is a common economic zone The key principles of the proposed system are likely to be: VATable supplies of goods and services A single standard VAT rate of 5%, 0% and exempt VAT exemption to be narrow the Government, health and education Financial services and free zones still under discussion Imports VATable at the point of entry into GCC Exports 0% rated Intra-GCC supplies of goods and services reverse-charge principle Mandatory and elective VAT registration thresholds Restriction on reclaim of input VAT on exempted supplies and non business expenses Page 18

20 Africa Folkert Gaarlandt Page 19

21 Africa is growing The African growth story Bridging the perception gap Individual African economies are among the fastest-growing in the world. Natural resources are a key driver of growth in Africa. The increasingly affluent one billion consumers will be the accelerator of growth. Regional integration and infrastructure investment will have a multiplier effect on growth. Africa is rapidly democratizing Corruption is a challenge but not pervasive It is getting easier to do business Human development is progressing African economy grew 3.5 times from 2002 total SSA GDP almost quadrupled One billion Africa s population 7 African countries among the 10 fastest-growing economies in the world % compound growth in FDI projects US$85 billion is the annual total of funding for African infrastructure in 2010 US$2 trillion is Africa s collective GDP US$400 billion is required South Africa s Government proposed infrastructure program Page 20 Around the world with VAT/GST on digital

22 South Africa electronic services Rules introduced on 1 June 2014: Electronic services are subject to VAT: No distinction between B2B and B2C Same application for intercompany transactions No reverse-charge mechanism everybody registers If an element of a service is subject to VAT, the entire service is subject to VAT Threshold is ZAR50,000 without any time limit Definition of electronic services is interpreted broadly Applicable if (two out of three): Recipient pays from a South African bank account Recipient has an address in South Africa Recipient is a resident of South Africa Page 21

23 South Africa electronic services Software was excluded: Subscriptions (of software) are included Most other types of services (video, games, music, etc.) are included Practical issues often around: Currency Invoices and invoice requirements Administration kept abroad Branches and cost recharges Notifications on e-filing Definition of electronic services is laid down in a regulation and can therefore be changed without having to go through Parliament Many companies have successfully obtained rulings around their specific circumstances Page 22

24 South Africa other Many dealings with South African Revenue Services (SARS) are electronic South Africa s role in African Tax Administration Forum (ATAF) Reportable arrangements Recent jurisprudence ABC Ltd., 4 March 2016 Nigeria VAT at 5% - one of the largest countries in the world by (population) No specific rules for electronic services Recent jurisprudence Gazprom June 2015 Recent jurisprudence Vodacom February 2016 Practice versus law Page 23

25 Other African countries Tanzania Kenya New VAT Act on 1 July 2015 Specific rules for B2C electronic services Distinction B2B and B2C Certain B2B transactions may also be captured Definition is almost equal to the South African definition Introduction of electronic fiscal devices more than 10 years ago Introduction of itax in 2013, mandatory as of August 2015 Page 24

26 Australia and New Zealand Brad Miller Page 25

27 Australia B2C imported services A tax integrity measure for maintaining GST neutrality for supplies made by non-resident entities, in line with the OECD s destination principles Key changes: Imposes a GST liability on the inbound supply of intangible products and services purchased for private consumption or by businesses not registered for GST Supplier required to take reasonable steps to determine GST profile of consumers GST liability can be shifted from the non-resident supplier to the operator/intermediary (electronic platform) between the supplier of digital products and the consumer, by mutual agreement This measure is to apply to tax periods starting on or after 1 July 2017 Page 26

28 Australia B2B cross-border transactions Designed to remove certain B2B supplies made by non-resident businesses from the Australian GST system, where the net GST impact is nil. Key changes: Non-resident suppliers not operating through an Australian establishment are not liable for GST on: Supplies of intangibles made to other non-resident entities Supplies made to Australian businesses that are registered for GST Maintain net GST revenue by utilizing the self-assessment/reverse-charge regime for inbound supplies of intangibles Remove incentive for refund-only registrations by extending GST-free treatment to supplies made to non-residents but received in Australia Subject to Royal Assent, changes could apply from as early as 1 October 2016 Page 27

29 Australia impact on resident and non-resident entities The implications of these changes could include: Suppliers making supplies to Australian private consumers may have to register for GST, and collect and remit it (from 1 July 2017). Suppliers currently accounting for GST on supplies that may now no longer be subject to Australian GST can cancel their registration (from 1 October). Domestic suppliers making supplies involving non-residents currently subject to GST are able to turn off the GST on those transactions (from 1 October). Page 28

30 New Zealand developments New Zealand has a wide-based single-rate GST system, which means, with very few exceptions, almost all domestic supplies are subject to 15% GST. From 1 October 2016, non-resident suppliers will be required to account for GST on supplies of remote services provided to New Zealand consumers. The proposed legislation broadly follows the OECD Guidelines as well as the rules that apply in other jurisdictions. The definition of remote services is very wide it includes all forms of services that can be provided remotely. Examples include: Most traditional services, such as insurance, legal and professional, and certain financial advisory All services that can be digitally provided, such as downloadable music, TV, movies, e-books, on-line gaming, and gambling Page 29

31 New Zealand developments B2C supplies of remote services: GST will apply from 1 October 2016 There are documentation requirements to identify NZ residents B2B supplies of remote services: Outside the scope of GST, unless the supplier elects to zero-rate The option to zero-rate is to allow the non-resident supplier to claim NZ GST incurred (if any) There are documentation requirements to identify New Zealand business customers If the documentation requirements are not satisfied, the transaction will be assumed to be B2C, which means GST will apply at 15% Subject to exceptions, an electronic market place (EMP) may be held liable instead of the underlying supplier: EMP is defined to mean a marketplace that is operated by electronic means through which supplies of remote services are made. A payment provider is not an EMP Special rules apply to insurers and gambling service providers Page 30

32 New Zealand developments Measures have been provided to make compliance easier: No double taxation rule Transitional provisions for fixed-term contracts New Zealand bank account requirement removed Records can be kept outside of New Zealand Quarterly GST return periods, except for the first, which is a six-month period (the norm is monthly and two monthly) Flexible arrangements concerning foreign currency Ability to agree an alternative method with the tax authority to determine the status of customers Simplified reporting for pay-only registered persons Losses for gambling supplies can be carried forward Page 31

33 Breakout to country tables Page 32

34 Breakout to country tables Africa Folkert Garrlandt Australia and New Zealand Brad Miller Brazil Sergio Fontenelle China Kenneth Leung India Gyanendra Tripathi Malaysia Aaron Bromley Middle East and GCC Jennifer O Sullivan Puerto Rico Gino Dossche Russia Olga Odintsova Page 33

35 Brazil and South America Overview Sergio Fontenelle Tel: Key developments for Brazil regulator level Increasing importance of indirect tax revenue on the total tax revenue matrix Indirect tax burden increase (nominal rates) Increasing focus on indirect tax compliance Increasing number of indirect tax audits and assessments Reduction of on-site audits Increasing focus on indirect tax data analytics to promote targeted audits and improve audit success Signs of streamlining compliance legal requirements Key developments for Brazil business level Acknowledgment that authorities utilize the tax data earlier than key stakeholders Increasing concern on the review of the indirect tax E2E process for risk mitigation and opportunity capture purposes Review of shared service center processes and operations Use of data as a source of insight (predictive analytics) Indirect tax department transformation into a strategic business aligned group Page 34

36 China Kenneth Leung Tel: Key developments for China regulator level Last stage of VAT reform starting 1 May 2016: Real Estate & Construction, Financial Services and Life Style Services to be subject to VAT Limited exemption and complex transitional measures Cancel the paper based VAT invoice verification one big step on digitization of fapiao handling Electronic VAT invoicing for normal VAT invoices (typically used by retail and other B2C as well as VAT exempt supply scenarios) Revised VAT filing forms, now 400+ data fields needed Planned indirect tax audits and assessments Key developments for China business level VAT reform rules set out in Circular36 contains many uncertainties led to lobbying needs for all many industry sectors Consolidate VAT filing becomes possible but taxpayers need to evaluate and obtain approvals from tax bureaus at city and provincial level (nationwide consolidation is not common) Engaging 3 rd party IT vendor on VAT management platform and fapiao handling outsourcing Increasing consideration of E-invoicing (US$1+/ invoice) and digitizing VAT compliance from VAT compliance cost management Page 35 Around the world with VAT/GST on digital

37 India VAT/GST on digital Gyanendra Tripathi Tel: Physical Sale vs. Digital Sale: Purchase/sale of tangible property FDI regulations in India permit only B2B marketplace model for ecommerce Purchase/sale of intangible property Tax implications/pos in case of: Purchase/sale of services B2B transactions Purchase/sale of real property B2C transactions PoS for - marketplace business vs. digital supply Concern areas: Tax type Tax jurisdiction Person liable to tax Credit availability Compliance C2C transactions Impact on transfer from one warehouse to another Ecommerce companies being treated as agents in some places In India, GST to boost e-commerce/digital economy by incorporating a solution to all the digital economy-related challenges Page 36

38 India VAT/GST on Digital Indirect taxes conventionally levied in India Service tax on marketplace commission model, aggregator electronic supply: Customs duty tax on import of goods within the country Excise duty tax on the manufacturer or producer on the manufacture of goods VAT/CST tax on the purchase/sale of goods Service tax levied for availing services Entry tax/octroi/lbt Tax on movement of the goods from one state to another Indian Central Government and state governments are forcefully legislating to tax the digital e- commerce, such as: Standard rate/special rate Value and abatement Credit restrictions States seeking VAT/CST registration/transaction information from the e-commerce players States are also seeking to levy entry tax on goods supplied though ecommerce model, though the originating states collect CST, which is negatively impacting on the supply chain Local authorities seeking to levy entry tax/local taxes on e- commerce/goods carriers Page 37

39 Malaysia Aaron Bromley Tel: Recently passed the one-year anniversary of the introduction of GST (1 April 2015) Audit activity by Royal Malaysian Customs Department on the increase Expectation of data analytics audit approach going forward Digital and e-commerce considerations and issues: Reverse charge is applicable for all imported services (where taxable in Malaysia) for business purposes, where supplier does not belong in Malaysia. Applies to both GST-registered and non-gst registered business recipients Ability for recipient to claim input tax dependent on taxable status No reverse charge applicable on imported services for non-business purposes potential implications for local suppliers of the same services No requirement to register for GST for non-resident entities making supplies of services consumed in Malaysia addressed by reverse charge Acquisition of goods from non-resident suppliers subject to import GST MYR500 (US$130) threshold per consignment (air) before GST applies Supply of goods in Malaysia (post-customs clearance) non-resident supplier liable for GST where registration threshold (MYR500,000/US$130,000 p.a.) is breached. Reporting and invoicing implications. However, non-residents can only register through local agents who assume the GST obligations and liabilities of the non-resident principal Page 38

40 Russia Olga Odintsova Tel: Expected changes: Special VAT rules for electronic services From 1 January 2017, Russia is planning to introduce special VAT rules for electronic services. The current approach is that place of supply of electronic services should be at the location of the customer. Foreign companies providing the electronic services to Russian customers or their agents (in certain cases) will be liable to VAT and registration in Russia. New rules for recovery of VAT incurred on purchases related to supplies taxed at 0% VAT rate It is planned to abolish special rules for that recovery of input VAT related to supplies taxed at 0% (upon collection and submission of documents confirming the 0% rate): the general rules will be applied instead. VAT application in case of advance payments It is expected that a draft law changing the VAT application in the case of advance payments will be adopted in In this case, VAT will no longer apply to a prepaid part of the transaction value at the moment of dispatch. VAT exemption on raw materials for medical devices It is proposed to clarify that the importation of raw materials for medical devices and component products that are not manufactured in Russia should be exempt from VAT. Other key indirect tax changes effective as of 2016 Documents evidencing that the parties have reached a mutual agreement on all essential terms of the transaction can be used as a contract confirming the application of 0% VAT. The threshold for an application of accelerated procedure for a VAT refund without a bank guarantee is decreased from RUB10 billion to RUB7 billion rubles of taxes paid for three preceding years. The insurance payment due to a supplier of goods owing to non-payment by the buyer should be included in VAT base if the supplier did not calculate that tax at the time of shipping. Producers of alcoholic beverages are obliged to make excise advance payments or provide a bank guarantee ensuring further excise payment. The validity of the bank guarantee should exceed the period of exemption from the advance payment. Page 39

41 Questions Page 40

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