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Protecting the tax base in the digital economytime as customs duties. To ease compliance, many countries allow anexemption for relatively low-value goods. 22In the case of imported services and intangibles, however,applying the destination principle to supplies of services and intangibleproducts is more difficult. The nature of services and intangiblesis such that there are no customs controls that can effectively confirmtheir exportation and impose the VAT at importation. Currently, thereare two approaches in dealing with the imposition of VAT to importedservices: (a) self-assessment by the importer under a so-called reversechargemechanism; or (b) a requirement for non-resident suppliers toregister for VAT purposes and to collect and remit the VAT. Underthe reverse-charge mechanism, registered VAT businesses whichimport services from non-resident suppliers (that is to say, businessto-businessor B2B) would have the onus of self-assessing the VAT (orcharging themselves the VAT) and claiming an input credit for a taxrefund. There is no net tax cost to the importer in such cases. However,if the importer is the final consumer and cannot claim any input credit,there is a risk that the importer would be motivated to abstain fromits duty, and not self-assess and remit the tax to the government. Itwould be very difficult for the authorities to enforce the reverse-chargemechanism in such cases. That is why some countries, such as SouthAfrica, introduced the registration requirement in respect of electronicservices, including educational services, games and gambling,information system services, Internet-based auction service facilities,maintenance services in relation to a website or a blog, subscriptionservices and the supply of e-books, films and music. 23 A non-residentsupplier must register for South African VAT if electronic services areprovided to residents in South Africa or where payment for such servicesoriginates from a South African bank.22For further discussion of VAT, see OECD, Action 1 — 2014 Deliverable,supra note 3, 41-48.23See press release by the National Treasury of South Africa, available athttp://www.treasury.gov.za/comm_media/press/2014/2014032801%20-%20Press%20Release%20-%20Electronic%20Services%20Regulations.pdf;Nyasha Musviba, “South Africa’s VAT changes: The impact on e-commerce,”(2014), available at http://www.sataxguide.co.za/south-africas-vat-changesthe-impact-on-e-commerce/2/.415

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