Out-Law Analysis | 24 Sep 2020 | 10:06 am | 2 min. read
Three out of the six Gulf Cooperation Council (GCC) states have now implemented VAT, with the remaining three due to follow by 2022.
The United Arab Emirates (UAE), Kingdom of Saudi Arabia (KSA) and Bahrain have all implemented VAT since signing the GCC VAT Framework in 2016. For the remaining three states of Qatar, Oman and Kuwait, there has been much debate over the most suitable timing for implementation taking into account the stability and strength of the domestic economy, trade, employment and other factors.
The current position for each of the three states is as follows:
While there have been no official announcements recently by Qatar in relation to the implementation of VAT, the state is currently expected to implement VAT in the second or third quarter of 2021.
The government and independent financial zone authorities continue to make progress with their regulatory legislative drafting. Qatar’s General Tax Authority (GTA) is also continuing with its ongoing preparations including the introduction of the state’s new tax administration system, Dhareeba.
Oman has to date been expected to implement VAT in early 2021, following a public interview by Bloomberg with Oman’s minister of commerce and industry at the World Economic Forum back in January 2020. However, in September 2020, a joint committee of the State Council and Shura Council recommended a 2022 implementation date, with the hope that Oman’s economy would be in a more positive growth position at that point in time.
Early preparation will allow businesses to avoid increased external implementation costs at premium rates due to late engagement, as well as pressure on internal teams to complete VAT preparations in a tight timeframe.
That being said, we understand that many stakeholders remain supportive of a 2021 implementation and a 2021 implementation date could still be chosen until such time as Sultan Haitham Bin Tariq Al Said approves the 2022 date via Royal Decree, which is expected imminently.
The Kuwait parliament’s support for tax reform appears to be somewhat lacking. However, it is still expected to implement VAT by 2022, according to a March 2020 report by the International Monetary Fund (IMF) - making it possibly the last of the GCC states to do so.
Businesses in the three states may generally feel that a formal implementation date must be announced before they commit any budget or resources to preparations for the new VAT regime, such as a change management plan. However, those in the region who have already been through VAT implementation would advise otherwise.
It is clear that revenue raising through taxes, including VAT, is firmly on states’ agendas given the immense pressures on local fiscal stability as a result of the Covid-19 pandemic and the oil price dip. This is reflected in the IMF Executive Board’s Article IV 2019-20 annual consultations for Qatar, Oman and Kuwait, together with publicly available state level financial plans.
Many government groups and international businesses have already begun their VAT readiness assessments for Oman and Qatar. Early preparation will allow them to avoid increased external implementation costs at premium rates due to late engagement, as well as pressure on internal teams to complete VAT preparations in a tight timeframe. Avoiding penalties for non-compliance is also seen as critical, given the high volume and significant value of tax penalties we have seen applied by tax authorities in states where VAT already applies.
Up-front strategic planning will be key to a successful VAT governance model, minimising time taken to implement as well as associated costs. This will include:
Senior management of the business should have GCC VAT governance on their agenda for the region so that early decisions, to which the VAT implementation change management project should be aligned, may be taken from a strategic perspective.
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