vat challenges for u.s. businesses in 2018 – changes in regimes, requirements, rules ... ·...

2018 U.S. Cross-Border Tax Conference

May 15 – 17, 2018

kpmg.com

VAT Challenges for U.S. Businesses in 2018 – Changes in Regimes, Requirements, Rules, and Reporting

AgendaIntroduction

Taxation of Digital Economy

VAT Challenges Associated with Supply Chains

The Impact of Tax Technology

India’s GST

0102030405

VAT in the GCC06

3© 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

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The following information is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.

Notices


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Today’s presentersName Title Firm | Company Name Email | Telephone

James Freed Principal KPMG LLP [email protected]

Brian Groome Managing Director KPMG LLP [email protected]

Philippe Stephanny Senior Manager KPMG LLP [email protected]

Jeremy Gray Senior Manager KPMG LLP [email protected]

Brandon Dart Manager KPMG LLP [email protected] 704-371-5248

Introduction


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The world of VAT

Source: OECD, Consumption Tax Trends 2016; WNT Research

9Countries

19Countries

24Countries

32Countries

44Countries

89Countries

119Countries

137Countries

152Countries

163Countries

171Countries

2014 2015+1969 1974 1979 1984 1989 1994 1999 2004 2009


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When can VAT be material for U.S. companies?At least 20 percent of revenue is derived from outside the United States.

The business has a large number of cross-border transactions, especially in the European Union.

A new business model or expansion of business activities is being considered.

The business is considering entry into new markets or countries.

Reorganization/merger/acquisition activity is planned.

ERP/tax engine or upgrades are being implemented.

Global service contracts are centralizing costs in the United States.

The business is in financial, real estate, or other “exempt” industry sector.

The business is involved in e-commerce (sales through catalogue or Internet sales).


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What can happen if you get it wrong?Underpaid VAT liability

Penalties and interest: Up to 200 percent of the VAT due, where not mitigated

Financial loss: For example, VAT becoming a real cost if irrecoverable or never paid by the tax authorities

Increased scrutiny going-forward of the tax processes by the tax authorities

Budget plans are inadequate to cover unexpected VAT costs.

The impact of material VAT liabilities on financial statements

Damage to business relationships. For example: — Customers being assessed for incorrectly charged VAT recovered on purchases— Charging VAT to customers, when incorrectly not included in the original invoice

Cost of correction:— Evaluation of errors and rectification of records and compliance filings— System and process updates/implementations

Taxation of digital economy


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Historical position:— Most countries traditionally applied the following rules to sales of services and intangibles:

- Business-to-business (B2B) transactions: VAT due in the country of the customer- Business-to-consumer (B2C) transactions: VAT due in country of the vendor

— Rules no longer fit for purpose in digital economy.

Digital services: VAT 101


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Global overviewRules enacted within last year Reforms under consideration Rules already in place European UnionUpcoming reforms


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Jurisdictions requiring a nonresident to register for VAT/GST for B2C sales of e-services:— Belarus (January 1, 2018)— Turkey (January 1, 2018)

- VAT registration portal started accepting registrations on April 4

Jurisdictions introducing VAT withholding on e-services purchases made by consumers from nonresident vendors:— Argentina (January 1, 2018) – implementing regulations pending — Uruguay (January 1, 2018) – implementing regulations pending — Brazil (ICMS Agreement on e-services effective April 1, 2018)— Colombia (July 1, 2018) – implementing regulations pending

Jurisdictions with new e-services rules


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Quebec:— Proposal released March 27, 2018— Proposed introduction of January 1, 2019 (non-Canadian digital platforms)— Proposed introduction of September 1, 2019 (Canadian based digital platforms)

Costa Rica:— Proposal released August 2017— Proposing to tax e-services via a withholding mechanism

New e-services rules proposed


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European Union: — Effective January 1, 2019:

- EUR 10,000: EU wide registration threshold for EU companies- EUR 100,000: simplified administrative requirements (one piece of evidence versus two pieces of evidence

currently) for EU companies- Allow non-EU business selling B2C e-services with a VAT registration in the EU to use the Non-Union Mini One

Stop Shop (MOSS) mechanism (currently, such businesses are required to register for VAT purposes in each EU member state where their consumers are established).

- Clarify that invoicing rules of member state of identification under MOSS apply (rather than invoicing rules where the consumer is located).

Amendments to existing e-services rules


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Russia— Since January 1, 2017, nonresident sellers of e-services to final consumers are liable to register for VAT in Russia— Effective January 1, 2019, nonresident of e-services to VAT registered customers in Russia will also be required to

register for VAT in Russia (currently a VAT withholding applies)

Switzerland— Effective January 1, 2018, the computation of the VAT registration threshold of CHF 100,000 is based on worldwide

sales rather than Swiss sales

Amendments to existing e-services rules


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VAT on low value importsAustralia:— Effective July 1, 2018:

- Sales of goods valued at AUD 1,000 are subject to Australian GST if the goods are purchased by consumers and are brought into Australia with the assistance of the seller.

- Deem an electronic distribution platform as the seller of low value goods if the goods are purchased through the platform by consumers and brought into Australia with the assistance of either the seller or the operator.

- Deem re-deliverers as the sellers of low value goods if the goods are delivered outside of Australia and the re-deliverer assists with their delivery into Australia as part of a shopping or mailbox service that it provides under an arrangement with the consumer.

- Allow nonresident sellers of low value goods that are connected with Australia to elect to access the simplified registration and reporting system.

New Zealand:— Proposal to apply GST on cross border B2C sales of low value goods (NZD 226 or NZD 400 depending on if they are

subject to duty) effective October 1, 2019 — Nonresident suppliers, online marketplaces or re-delivers would be required to register for and collect GST

depending on the circumstances


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European Union:— Effective July 1, 2021:

- Repeal of distance selling rules and exemption for imports of small consignments- Expansion of MOSS scheme to EU companies making cross-border sales of goods to consumers in other

EU countries for more than EUR 10,000 - Expansion of MOSS scheme to non-EU companies making sales of small consignments with a maximum

value of EUR 150 — Provided that certain conditions are met, no import VAT becomes due in the country of importation,

but in country of the consumer.

Russia:- Russian Ministry of Finance proposed lowering VAT-free threshold for imported goods - From July 1, 2018 the threshold will be cut from EUR 1,000 to 500 per import- From January 1, 2019 the threshold will be dropped to EUR 200

VAT on low value imports


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U.S. Supreme Court heard oral arguments in South Dakota v. Wayfair on April 17, 2018South Dakota asked the court to revisit/abrogate Quill’s sales/use tax physical presence nexus requirement and uphold economic nexus standards for remote sellers

Thoughts after the oral arguments:Whether Quill will be overturned is perhaps less likely than it was before the argumentsCourt concerned with three issues: — Costs and burdens on sellers;— Retroactivity;— Congressional action/inaction

Decision expected by late JuneMeanwhile, states continue to enact nexus expansion standardsE.g., Idaho, Alabama, Oklahoma

U.S. sales and use tax considerations

VAT challenges associated with supply chains


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As a consequence of new U.S. international tax provisions (e.g., GILTI & BEAT) MNEs may be considering:Restructuring existing supply chains — Need to consider VAT to avoid VAT leakage, etc.U.S. multinationals may consider replacing foreign branches with fully owned subs: — Creation of new VAT taxpayer — VAT consequences of transfer of assets from branch to subsidiary— Potential VAT audit of historic liability— Preferential VAT treatment (out of scope) no longer applicable to head office – branch transactions

Global contract restructuring to exclude U.S. involvement in non-U.S. operations — Potential additional VAT issues

U.S. tax reform & supply chain considerations


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Requirement to register for VAT in a jurisdiction is generally triggered when a business is deemed to have made a sale in that jurisdiction (subject to local discretions/regimes).

As a result, when a company provides goods or services, it must determine the sourcing for each good or service to understand the VAT impact.

VAT registration triggers

Goods and services have different sourcing rules

Certain types of services have special

rules (e.g. digital content)

Sourcing rules can differ by jurisdiction

(though some harmonization in

the EU)

Challenges


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Electronically supplied services:— Consumer location

Mergers and acquisitions

Supply chains:— Contractual documentation vs. commercial reality— Distribution structures - movement of own goods, consignment stock, inventory locations, etc.— “Importer of Record”

Shared Service Centres

Intercompany transactions— Invoicing/reporting— Recharges to pure holding companies

Flash title sales

Common global challenge triggers


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VAT generally applies to all activities divided in two categories:

VAT can get trapped in a supply chain!

Transactions within the scope of VAT

Sales of Goods

• Sale of tangible property• Certain other transactions

qualify as sales of goods (e.g., sale of water and electricity)

Sales of Services

• Any transaction which does not constitute a sale of goods

• Includes also intangibles and transfer of rights


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Single vs. Multiple Sales— Relevant where goods or services are sold on their own: some elements would be

taxable and others would qualify for VAT relief

Single Sale— One overall type of sale— One VAT liability

A Sale to Better Enjoy the Principal Sale— VAT liability follows the principal sale

Mixed Supply— Two or more components are separate sales— Each sale has its own VAT liability

Transactions within the scope of VAT


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Distinction between two principles of determining which country is authorized to levy VAT

GoodsGenerally taxable where consumption occurs— Follow the flow of the goods— Exports are generally not taxed— Imports are generally taxed

ServicesDue to intangible nature, proxies must be used— E.g., where customer is established, immovable property is located, work is performedHowever, increasing number of jurisdictions adopt destination based taxation for digital services

In which country is VAT due?


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Global contracting & VAT

U.S. Parentco

Dutch Tradeco

Japan Tradeco

UK Holdco

UK Tradeco

Irish Branch

•Sale of goods•Provision of services

U.S. Based Vendor

1. Customer contracting entity?2. Nature of sales3. Delivery arrangements4. Payment arrangements


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Sourcing rulesShip to?Transfer of ownership to whom?Status of transferee?

VAT documentsInvoices, credit/debit notes – specific content requirementsImport documentation

Others (non-VAT documents):Purchase orders, sales orders, delivery documentation – import/exports (SAD)Contracts related to the specific supply

Sale of goods to a centralized purchaser


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Sourcing rulesType(s) of service(s) being supplied?Identifying recipient of services?Status of service recipient?

Place where service recipient has established its business

Place where service is used/consumed

Service recipient with additional “fixed establishments”

VAT documentsInvoices, credit/debit notes – specific content requirementsImport documentation

Others (non-VAT documents):Purchase orders, sales ordersContracts related to the specific supply

Sale of services to a centralized purchaser

The impact of tax technology


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Considerations for high performing tax functions

In today's complex tax and business landscape, as expectations for global transparency heighten and real-time information sharing across jurisdictions becomes increasingly common, tax technology is emerging as one of the most important enablers of effective tax department design and delivery. Indirect Tax Technologies developed to help tax departments to adapt to regulatory change, streamline processes, experience enhanced reporting and simplified data management, and enable effective collaboration across the tax department and beyond.

Tax technological solutions come in many different forms to need the various needs of all companies, including: direct ERP integration with a tax engine, custom solutions, cloud based systems and automated batch processes.

People

Process/ Controls Technology

Data


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The continued complexity around indirect tax and some of the external pressures require tax leaders to do more and deliver more with less. Technology is increasingly becoming part of the solution.

However, it is important to remember that:— There is no one-size-fits-all solution, and no one answer that works for business.— For some companies, the less-advanced solutions can still have merit.— For many if not most, however, the more advanced options will tend to deliver greater value.

Options:— Native ERP – Built-in functionality within an ERP e.g., SAP, Oracle, and JDE— ERP customization for the businesses’ specific VAT needs — Tax engine – Indirect Tax software e.g., Vertex, OneSource, Avalara AvaTax, and Sovos (formerly Taxware)— Tax Data Warehouse

Automation options


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Potential automation benefits

— Ease of embedding controls— Better and centralized management

of tax decisions/treatments— SOX and security controls— Enhanced audit trail

— Time savings— Cost savings e.g., training and research— Easier to manage overseas compliance

and localization issues— Eliminate manual processes— Reduce reliance on IT for reports— Ease of managing big data Operational

efficiencyBusiness

enablement

PlanningRisk management

— Better control and insight of data— Enhanced management reporting

capabilities— Tools to easily work with/model

tax data— Time freed up for strategic

decisions and value-add activities

— Better tools to manage complex transactions

— Greater flexibility and control to adapt to business changes

— Geographic expansion— Regulatory changes— Product line expansion— Merger/Acquisitions


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Automating the indirect tax end-to-end process

Options:— Native ERP functionality— ERP customization or “bolt on”— Tax engineObjectives:— Effective application of tax policy— Automation of tax calculation and controls— Reduced error rates and better compliance

Options:— Standard “global” ERP reports to meet all

filing requirements— Automated compliance software to process

ERP data Objectives:— Standardized reporting processes— Reduction in manual processing and

associated errors— Reduction in time to complete returns

Options:— Control reports built in ERP or data

warehouse— Data analytic toolsObjectives:— Identification of errors or mispostings— Greater control over manual processes

such as accounts payable— Trend analysis

Detective controlsPreventative controls

General ledger ReportingTransaction processing

Post-transactional adjustmentsMaster data Tax determination

logic

Output VATG/L account

Input VATG/L account

VAT controlG/L account

VAT returnprocess

SalesprocessingO

rder

en

try

Ord

er

entr

y Purchase processing

Credit notesBad debts

Credit notesaccruals

Customer master data

Product data

Supplier master data

AR VAT logic

AP VAT logic

End-to-end process

Determination and calculation Analysis Reporting


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What are some of the consideration and questions a business should be asking to determine the most appropriate strategy for its tax technology needs:— How complex is the business supply chain from a VAT perspective? — What is the global VAT footprint of the business and what countries need to be covered? — What are the business critical requirements and scenarios, and how does this compare to the “out-of-the-box”

functionality versus the need for customization?— Does the business need tax support from the software provider, and if so, how much?— Does the business have the ability to maintain and update the tax content for changes to VAT legislation, VAT rates,

and VAT treatments?— What level of automation is required for the VAT compliance preparation process?— What is the time line for implementing the Tax Engine/ERP solution?— Does the business plan on outsourcing part of the VAT compliance process or will it be managed in house?— If a Tax Engine solution is preferred, how compatible and how easily can it be integrated with the ERP?— What is the size of the budget for one-off costs (i.e., implementation) and the ongoing costs (e.g., licensing)?

Key considerations


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There is a common and mistaken assumption that tax “content” essentially translates to “rates.” This is not accurate. It goes much deeper. Content includes:— Product and service taxability— Special tax situations (exemptions, holidays, etc.)— Taxable basis— Deductibility and recoverability— Legal requirements and content for invoices and other tax documentation— Tax accounting information— Rates across multiple countries and jurisdictions.

Again, it is extremely hard to manage data sets of this depth and granularity without the support of technology.

The “content” myth


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The pros and cons (ERP versus tax systems)Criteria Native ERP Indirect tax systemsMonitoring tax law and rate changes Ease/speed of implementation One-off costs Ongoing maintenance costs Dealing with complex tax structures Ease of maintenance Ability to carry out complex tax determinations and calculations

Ability to automate return preparation Adaptability/flexibility for business model changes

Localized tax capabilities


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People

Process/ Controls

Technology

Data

Regardless of what area of tax you work in—whether it’s corporate income tax, indirect tax, property tax, trust tax, tax information reporting, or transfer pricing—there is an emphasis on managing the end-to-end tax process, without duplicating work.

There are new technologies in the market that enable the tax department to eliminate mundane repetitive work and focus on more important initiatives. These tools provide tax with ways to manipulate mass amounts of data at high speeds and the ability to automate these processes with robotics.


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The path to cognitive automationReshaping the workforce

Machine learning

Deep learning

Artificialintelligence

Natural languageprocessing

Predictiveanalytics

Text analytics

Imagerecognition

Voice recognition

Intelligent augmentationA new partnership between

humans and machines

Physician Nurse WealthAdvisor

InsuranceAdvisor

SalesAdvisor

LegalAdvisor

TaxAdvisor

Auditor


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AlteryxCleanse and join data from different sourcesMore tools to build and publish analytic modelsBuild LogicCompare / Reconcile Data Sources

Tools to automate data processes


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Process automation solution market demands

Minimize risk

Eliminate repetitive tasks

Enable tax team to work on more strategic value adding activities

Minimize time spent on manipulating data

Speed up compliance processing cycles


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People

Process/ Controls

Technology

Data

Big data is revolutionizing how business and consumers behave, make decisions and interact.

All about extracting mass quantities of data from our systems, transforming the data, running exceptions and calculations, and then providing visualizations back to the users for analysis.

Tax is one of the biggest users of data in a business, amongst which indirect tax is the primary user of data.

System based audits from tax authorities and scrutiny by management, makes this area even more crucial for tax.

Potential for far greater insights then ever before.

Using the same old two dimensional methods and asking same old questions doesn’t make sense.



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KPMG’s indirect tax benchmark survey highlights

Technology is the key investment priorityOver the 3 next years, indirect tax leaders say they intend to make technology their top priority for investment. This shows indirect tax functions are recognizing that technology is becoming ever more critical as governments move toward digital data delivery and direct access to organizations’ tax and financial accounts.

Which of the following do you plan to invest more in, in the next 3 years?

Overall 74%

Technology Data & Analysis Process People None

48% 47% 37% 7%

Risk management appears to be decreasing as centralization increasesIn the area of risk identification and controls, indirect tax functions increasingly say that they have identified key indirect tax risks across regions. However, a sizable minority have yet to identify their exposures to indirect tax risk in the Asia Pacific region or Latin America, which could adversely affect their cash positions.


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What is data analytics?

It takes business-minded technology people and data-minded business people to work together to drive real value for the business.

Analytics isn’t about putting a bunch of techies in a room with some tools and hoping that something valuable comes out. “ ”*Dr. Thomas Erwin, Partner, KPMG in Germany


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Data challenges

Business applications do not meet tax department needs

• Tax gets left behind in system implementations

• Tax is low priority for many IT departments

Systems are not integrated • Can’t find anything when you need it

• Corporate retention policies are often not structured or indexed

• Acquired company data resides in separate applications

Current tax technology is fragmented Separate tax tools for • Compliance and tax calculation• Management reporting• Audit Defense

Tax authorities are increasing data requests • Extent of electronic information requests is increasing

• Requests for direct system extracts or connectivity are increasing

• The time to produce the information is decreasing

• Authorities expecting more data sooner in the process

Data is driving the tax department


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Data and analysis (D&A) – market demands

Reduce the Tax & IT divide

Ability to validate transactions on monthly basis

Ability to monitor tax decision/systems logic in existing solutions

Reduce consulting costs for reverse audits

Increase visibility of end to end process for tax

Ability to assess effectiveness of business controls e.g. Master data

Spend less time gathering and pulling data and more time on analysis and value add business partnering

India’s GST


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Overview of new indirect tax system

— Tax on all supplies

New GST

— Excise duty, CVD, SAD, service tax, VAT, CST, entry tax, purchase tax, entertainment tax, luxury tax, and cesses

Subsumed

— Dual GST for central (CGST) and states (SGST), IGST on interstate supplies

New mechanism

— Full credit of all GST paid, except cross credits between CGST and SGST

Credits

— State GST laws follow same model law approved in advance by GST Council— Rules harmonized between central and states— Streamlined administration

Streamlined approach


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Multiple tax rates with peak rate going up to 40 percent

Concept of matching supplier and buyer data for claiming tax credits – complex return filing process

No concept of grouping registration in each state in which activity is performed

Unique e-waybill system to track movement of goods within India

Cash flow under reverse charge mechanism

Anti-profiteering rules— The benefit of tax reduction and tax credit shall be passed on to the end recipient of such goods or services— Several large taxpayers are already under investigation by National Anti-Profiteering Authority (NAA)— Unclear how “tax advantage” is assessed

Unique complexities of India’s GST system


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Every taxpayer is required to file at least 37 returns on an annual basis:— Three returns per month (outward, inward, and monthly return) Each return contains 10 to 13 detailed tables and numerous other details, e.g.:— B2B interstate supplies— B2C interstate supplies— HSN summaryDue to issues in the GSTN:— Filing deadlines for initial GST returns is regularly postponed by GST Council.— The present system of filing of GSTR 3B and GSTR 1 has been extended for another three months, i.e.,

April to June 2018:- Will remain extended until the new and simplified process of filing returns is finalized

Continuous changes— GST rates updated regularly by GST Council— E-waybill system progressively implemented effective April 1, 2018 for inter and intra-state consignments

worth at least INR50,000 ($780)— Liability to pay VAT under reverse charge mechanism deferred until June 30, 2018 — The provisions for deduction of tax at source (TDS) and collection of tax at source (TCS) remain suspended

until June 30, 2018Likely upcoming changes:— GST Council considering simplifying GST returns and GST registration requirements

Compliance challenges

VAT in the GCC


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What is the Gulf Cooperation Council (GCC)?— Kingdom of Bahrain, State of Kuwait, Sultanate of Oman, State of Qatar, Kingdom of Saudi Arabia (KSA),

and United Arab Emirates (UAE)

Unified Council of Agreement for Valued Added Tax of the Cooperation Arab States of the Gulf— Published May 2017— Establishes harmonized 5 percent VAT throughout the GCC with local country-specific rules

Status of VAT implementation— Kingdom of Saudi Arabia and UAE have introduced VAT effective

January 1, 2018— Commitment for remaining countries to adopt VAT within 12 months after

the first two member states have implemented it. However, there is no real sanction if a GCC member state does not comply: - Bahrain: likely October 2018- Kuwait, Oman, and Qatar: likely in 2019

Gulf Cooperation Council


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Broad-based 5 percent VAT applicable to all sales of goods and services sourced to the particular jurisdiction, with very few exceptions:— Exemptions:

- Financial services (including life insurance and Islamic finance), excluding fee-based revenue – KSA + UAE- Residential real properties – KSA + UAE- Local passenger transport – UAE - Bare land – UAE

— Zero-rated transactions:- Exports of goods and services – KSA + UAE- International transportation and related sales – KSA + UAE- Sales of medicine and medical equipment – KSA + UAE- Certain investment grade precious metals – KSA + UAE- Newly constructed residential properties (i.e., first-time sale within three years of their construction) – UAE- Certain education services and relevant goods and services – UAE + KSA for Saudi citizens- Healthcare services and relevant goods and services – UAE + KSA for Saudi citizens- Supplies of certain sea, air, and land vehicles – UAE

Overview of VAT in KSA and UAE


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Rules modeled based on international standards, including EU, e.g.:— Imports of goods and services are taxed.— Exports of goods and services are zero-rated. — Nonresident sellers must register and collect VAT in KSA and UAE for sales electronic supplied services

(e-services) to consumers.— Requirements to issue VAT compliant invoices and file periodical returns (in general quarterly).

Particularities:— GCC Agreement includes special rules for intra-GCC supplies:

- Not enforced in KSA and UAE: All intra-GCC supplies follow import/export rules.— Discrepancy between VAT law and customs/commercial laws:

- Nonresidents cannot import goods without a commercial license and must thus use a local agent to import goods.- UAE explicitly covers imports by agents versus KSA not mentioned

— Voluntary registration threshold (expenses)— Free zones in UAE:

- Not all free zones qualify as designated zones for VAT purposes.- Only sales of goods are outside the scope versus services are taxable.

Key takeaways and challenges


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Lack of clear guidance:— KSA and UAE released sometimes very late key information (e.g., UAE decree on free zones was

published on December 28, 2017).— Laws and regulations are often not detailed enough.— Technical and industry specific guides are slowly published by tax authorities.

- KSA guide on financial services available in English only in April 2018

Strict enforcement:— According to news reports, tax authorities have already started issuing penalty notices for late registrations,

issuance of wrong invoices, and not submitting requested information.

Focus on compliance:— UAE and KSA authorities have called on taxpayers to file returns before February 28 deadline.— On January 17, 2018, UAE tax authority announced extension between one and three months for VAT return

submissions for certain designated businesses.

Key takeaways and challenges (continued)

Thank you

© 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 613174

The KPMG name and logo are registered trademarks or trademarks of KPMG International.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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vat challenges for u.s. businesses in 2018 – changes in regimes, requirements, rules ... ·...

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