CA ANZ has lodged a submission to the Board of Taxation (BoT) on its Review of the GST on Low Value Imported Goods (LVIG) measure.  Key points in our submission included:

• CA ANZ, through our Indirect Tax Committee, worked closely with Treasury and ATO officials in a collaborative process during the development phase of the new LVIG measure to co-design and co-develop a measure that would be as workable and effective as possible.
• In our submission to the Productivity Commission in 2017, we supported the legislated vendor collection model for LVIG. Based on our assessment of its performance over the past three years since implementation, we continue to support it judged by its performance on:
  • tax neutrality between foreign and domestic suppliers;
  • GST revenues;
  • administrative and compliance costs; and
  • impacts on consumers and business.
• CA ANZ believes that the LVIG measure has been broadly effective especially with larger entities, recognising that it is an impossible task to reach every non-resident entity supplying goods to Australia.
• The compliance burden has not been unduly onerous for most entities, especially given the simplified registration option. The requirement for Electronic Distribution Platforms (EDPs) to account for supplies made through their platforms has also removed the compliance obligations from small suppliers.
• There is however an issue about how to bring further non-resident entities into the LVIG regime, especially if they only become recently aware of their obligations – the evident problem being an unanticipated retrospective tax liability from 1 July 2018.
• We recommend the BoT conduct a further review of GST on imported goods and services in 3 to 5 years, also covering mechanisms and technology solutions that may enhance compliance e.g. block-chain administration and/or enhanced administrative obligations on the EDPs who facilitate such commerce.