Saturday, January 31, 2015

The ASEAN Single VAT Law

I.                   Introduction

A.     Background of the Study

“In this world nothing can be said to be certain, except death and taxes”
Benjamin Franklin, Letter to Jean Baptiste Le Roy, 13 Nov. 1789

In its broadest sense, taxation is the imposition by the state by virtue of its sovereignty, of a charge or burden either on a person, property or property rights with the end in view of raising needed revenue for the support and operation of government.[1]  

In Panay Electric vs. CIR and CA (G.R. No. L-10574 dated May 28, 1958), the Supreme Court had the occasion to provide a conceptual definition of a tax, it goes on to state that such is a forced charge, imposition or contribution; it operates in invitum, and is no way dependent upon the will or contractual assent, express or implied, of the person taxed.

Clearly, the importance of tax in our daily lives is so profound and unavoidable. The ASEAN Economic Community Integration, which aimed to promote free movement of goods, services, investments and skilled labor as well as capital flows among ten ASEAN countries, has been postponed[2] twice due to challenges encountered in implementing some of its phases, center of these challenges is the uncoordinated and diverse tax policies of the member countries.

Generally, taxes are classified into direct and indirect. Direct tax is a tax for which a taxpayer is liable on the transaction or business it engages in, without transferring the burden to someone else. While an indirect tax is a tax wherein the seller of goods or services may pass the amount of tax paid to the buyer, with the seller acting merely as tax collector. In indirect taxes, the burden of taxation falls on the immediate buyers and ultimately, the end consumers. [3]  Examples of direct taxes in the Philippines are individual and corporate income taxes, transfer taxes and residence taxes, while one widely known example of an indirect tax is the Value Added Tax (VAT), also known as Goods and Services Tax in some countries.

In line with the on-going integration of the countries of the ASEAN Region, it is but just a matter of time that all ten ASEAN countries will adopt a uniform tax system. This fact pattern can be observed upon the emergence of the European Economic Community or commonly known as the European Union.

B.     Significance of the Study

Though not explicitly declared, it is quite convincing that the success of the European Union success of the European Union serves as the inspiration for the establishment of the ASEAN Economic Community. Needless to say, the blueprint and integration activities has been patterned with the European Union Integration Checklists.

As far as the Author is concerned, there has been no detailed research output outlining the similarities and difference of the EU Single VAT Law and ASEAN countries’ business tax and VAT laws. Also, a Single VAT Law applicable to all ASEAN countries has never been tried to be formulated.

C.     Scope and Limitation 

This research paper will focus on analyzing the different EU VAT Directives and the different business tax and VAT laws of ten ASEAN countries. Such analysis aimed in identifying similarities and conflicting provisions of tax rules and regulations to facilitate in coming up with a uniform VAT law applicable to the entire ASEAN region.

The social impact on the application of the ASEAN Single VAT Law to each of the ASEAN countries will not be discussed in details. Also, this research paper will not be discussing the effect of the change of tax policies to other type of taxes such as corporate income tax, customs duties, withholding taxes and documentary stamp taxes.




[1]  State vs. Thorne, 87 N.W. 797
[3]  ABAKADA Guro Party List vs. The Executive Secretary, G.R. No. 168056 dated September 1, 2005

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