Draft OECD guidelines for VAT neutrality.

• Position: Organisation for Economic Cooperation and Development, value-added tax

March 30, 2011

On March 30, 2011, Tax Executives Institute submitted the following comments to the Organisation for Economic Co-operation and Development supporting its Draft Guidelines for VAT/GST Neutrality. The comments were prepared under the aegis of its European Indirect Tax Committee, whose chair is Jean-Daniel Rouvinez of Tetra Pak International. Contributing substantially to the development of TEI's submission was Lynne Clare of Sony. Jeffery P. Rasmussen, TEI Tax Counsel, serves as staff liaison to the European Indirect Tax Committee and coordinated the preparation of the Institute's comments.

On 22 December 2010 Working Party Number 9 on Consumption Taxes of the Organisation for Economic Cooperation and Development (OECD) released a consultation document setting forth its Draft Guidelines on Neutrality. The final document will be incorporated as Chapter 1, Sections 1 and 3 of the OECD International VAT/GST Guidelines. As President of Tax Executives Institute, I am pleased to submit the following comments on the consultation document.

Tax Executives Institute

Tax Executives Institute was founded in 1944 to serve the professional needs of business tax professionals. Today the organisation has 54 chapters in North America, Europe and Asia. As the pre-eminent international association of business tax professionals, TEI has a significant interest in promoting tax policy, as well as in the fair and efficient administration of the tax laws, at all levels of government. Our 7,000 members represent 3,000 of the largest companies in the United States, Canada, Europe and Asia.

In 1999, TEI chartered a chapter in Europe, which today encompasses a cross-section of European and multinational companies. TEI members are accountants, lawyers and other corporate and business employees responsible for the tax affairs of their employers in an executive, administrative, or managerial capacity. The Institute espouses organisational values and goals that include integrity, effectiveness and efficiency, and dedication to improving the tax system for the benefit of taxpayers and tax administrators alike.

General Comments

TEI commends the OECD and Working Party Number 9 for the ongoing efforts to develop international VAT/GST guidelines. In today's highly globalised business environment--with many businesses including small and medium-sized enterprises and large multinational corporations, engaged in cross-border trade and with more than 150 countries...