亚开行-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（英）

ISSUE 60 • 2025The Governance BriefTaxing Cross-Border E-Commerce Supplies: Lessons from Value-Added and Goods and Services Tax Policies in Australia and Viet Namby Gary ArtusoThe production of this brief was sponsored by the Domestic Resource Mobilization Trust Fund of the Asian Development Bank (ADB). It was prepared under the guidance of Yuhei Chiba, public sector specialist (Taxation), and written by Gary Artuso, international value-added tax (VAT) consultant.Thanks to ADB staff Sandeep Bhattacharya, principal sector specialist (Taxation); Yuya Yamamoto, trade specialist; Kozue Ichiyama, public sector specialist (Taxation); and Chinmaya Goyal, senior economics officer (Public Finance), for guiding to ensure that the brief effectively addresses the key issues and components of VAT on cross-border e-commerce transactions while supporting ADB’s developing member countries in designing and implementing VAT reforms. This brief also greatly benefited from the ADB internal paper Developing and Implementing an Approach to Applying Value Added Tax to Cross-Border Digital Supplies, which served as a valuable background resource.Notes: In this publication, “$” refers to United States dollars, “A$” refers to Australian dollars, and “D” refers to Vietnamese dong. ADB recognizes “Vietnam” as Viet Nam.1 Organisation for Economic Co-operation (OECD)/World Bank Group (WBG)/Asian Development Bank (ADB). 2022. VAT Digital Toolkit for Asia-Pacific. OECD.2 ADB. 2023. E-commerce Evolution in Asia and the Pacific: Opportunities and Challenges.IntroductionValue-added tax (VAT) accounts for more than 20% of total tax revenues in Asia and the Pacific.1 As the e-commerce market continues to grow across the region, adapting VAT regimes to capture tax revenue from digital transactions—particularly cross-border digital transactions—is a key policy measure to strengthen domestic resource mobilization.2The destination principle is the widely accepted rule for applying VAT to cross-border transactions. Under this principle, VAT is levied in the country where the goods or services are consumed. For international trade in goods, the obligation to account for VAT in the destination country typically depends on which party acts as the importer. For services supplied by overseas businesses, the overseas suppliers would traditionally establish a physical presence in the customer’s jurisdiction, The Governance Brief2where they would be required to register and account for VAT. These arrangements allow tax administrations in the destination country to trace and monitor supplies for enforcement purposes. In most cases, VAT is not due in the supplier’s country, and the supply is treated as a nontaxable export. In contrast, the business model of digital supply—such as streaming of movies and music and the purchase of goods from large online platforms—does not require suppliers to have a physical presence in a destination country. The rapid growth of cross-border e-commerce challenges