对跨境电子商务供应征税：澳大利亚和越南增值税和商品及服务税政策的教训

Taxing Cross-Border E-CommerceSupplies: Lessons from Value-Added by Gary Artuso Introduction The destination principle is the widely acceptedrule for applying VAT to cross-border transactions.Under this principle, VAT is levied in the countrywhere the goods or services are consumed.For international trade in goods, the obligation to Value-added tax (VAT) accounts for more than20% of total tax revenues in Asia and the Pacific.1As the e-commerce market continues to growacross the region, adapting VAT regimes to capture registration threshold to nonresident suppliersthat is consistent with the threshold fordomestic businesses.4When a nonresidentsupplier below this threshold sells goodsor services to final consumers or certainVAT-unregistered businesses in the importingcountry, no VAT is collected in the importingjurisdiction as the supplier is exempt fromVAT obligations. Although it was previously where they would be required to register andaccount for VAT. These arrangements allow taxadministrations in the destination country to traceand monitor supplies for enforcement purposes. In In contrast, the business model of digitalsupply—such as streaming of movies and music andthe purchase of goods from large online platforms—does not require suppliers to have a physicalpresence in a destination country. The rapid growth (i)Enforcement challenges in taxing supplierswithout a physical presence.According to thedestination principle, the importing countryhas the right to tax cross-border e-commercesupplies. However, unlike traditional brick-and-mortar businesses, digital suppliers can operateacross borders without establishing a physical (iv)Increase in low-value imported goods.Many countries apply a de minimis thresholdunder which imported goods are exemptedfrom VAT and customs duties. Before therise of e-commerce, such exemptions (ii)Competitive distortion between domesticbusinesses and overseas online vendors.While local businesses collect and remit VATon digital supplies, nonresident e-commercesuppliers providing the same goods or services Overview of VAT/GST Schemes—OECD Framework The Organisation for Economic Co-operationand Development (OECD)/G20 Base Erosionand Profit Shifting (BEPS) Project has identifiedthese challenges.5Under the OECD/G20Inclusive Framework on BEPS, jurisdictions are (iii)Increase in small-scale nonresidentsuppliers below the VAT registration implementation guidance notes and papers on VATpolicies related to digital trade.6The developmentof the implementation guidance resulted from Figure 1 represents the key features of aneffective VAT system for nonresident suppliers. The following sections compare thearrangements implemented by Australia andViet Nam, two economies that have demonstrated As of 2025, more than 100 jurisdictions—including many developing economies—haveimplemented reforms based on the OECD VATstandards and guidance, with over 30 othersconsidering reform.7The guidance issued by OECDis designed to allow jurisdictions to preserve VATrevenue and promote a level playing field betweene-commerce and conventional business models. The VAT and goods and services tax (GST)regimes of Australia and Viet Nam are alignedwith OECD guidance and designed to enhancetheir capacity to address nonresident e-commercesuppliers.8However, their regimes are tailored By examining the policy choices andadministrative mechanisms adopted in Australiaand Viet Nam, this brief aims to help jurisdictionsconsidering reforms gain a clearer understanding of Like Viet Nam, it also has its own localonline shopping marketplaces, such as Catch,My Deal, Iconic, and Kogan.11These channels offerseller-friendly platforms for local and international In both countries, the governments haveintroduced laws, policies, and processes to makenonresident e-commerce suppliers responsible forapplying and collecting VAT on remote supplies.This has resulted in significant revenue outcomes Comparative Analysis of Australiaand Viet Nam’s Economies Table 1 provides a simple economic snapshot Viet Nam’s economy is among the fastestgrowing in Asia. Its e-commerce sector grewby 20% in 2024, bringing the market sizeover $25 billion. This is driven predominantlyby mobile commerce, according to the Ministryof Industry and Trade.9Viet Nam’s top online Table 2 presents the share of VAT/GST in totaltax revenue along with that of other taxes. The data in Table 2 provide a snapshot of thetax environment that impacts consumption tax lawsin Australia and Viet Nam. Australia’s GST law hasremained largely unchanged since its introductionin 2000, aside from minor adjustments. In contrast, In comparison, Australian households spentA$69 billion (about $45.5 billion) on e-commercein 2024, reflecting 12% year-on-year growth. VAT accounts for a larger share of tax revenuein Viet Nam than GST does in Australia. VAT inViet Nam plays a significant role in the country’seconomic development and public finance. By GDP = gross domesti