【联合国贸易发展委员会】电子商务和数字贸易的间接税：对发展中国家的影响-2025_155页_4mb

Summary of Indirect Taxation of E-commerce and Digital Trade in Developing Countries

Introduction

E-commerce and digital trade are rapidly growing globally, presenting both opportunities and challenges for tax systems in developing countries. Digitalization expands access to markets but complicates tax collection due to cross-border transactions, non-resident vendors, and informal economies. This summary explores key implications, challenges, opportunities, and policy recommendations for indirect taxation, with a focus on value-added tax (VAT) and digital trade.

Key Trends in E-commerce and Digital Trade

• Growth: E-commerce sales reached approximately $27 trillion in 2022, with significant post-pandemic increases in developing economies. Online shopping adoption varies widely, from under 5% in some countries to over 80% in others.
• Definitions: E-commerce includes all digital orders, while digital trade involves electronically ordered or delivered goods/services. Key challenges arise from distinguishing between domestic and cross-border transactions.
• Economic Impact: The rise of digital platforms and services creates new revenue sources but risks unfair competition by exempting some imports from traditional taxes.

Taxation Challenges

• Revenue Erosion: Digital trade erodes tax bases due to non-resident vendors, informal operators, and de minimis rules that exempt low-value imports (e.g., under $400 in some countries).
• Informal Economy: Up to 51% of GDP in some developing countries comes from informal activities, reducing VAT collection potential. Digital tools exacerbate this by complicating transaction tracking.
• Administrative Barriers: Limited tax administration capacity, outdated systems, and insufficient digital infrastructure hinder compliance efforts.
• Cross-Border Issues: Unclear nexus for taxing remote transactions, double taxation agreements (DTAs) limiting withholding mechanisms, and difficulties enforcing tax laws on non-resident entities.

Opportunities and Solutions

• VAT Implementation: VAT is a major revenue source in many developing countries, accounting for ~30% of tax revenue on average. Digitalization can enhance collection through automated systems, e-invoicing, and electronic payment platforms.
• Simplified Registration Regimes: Tools like the OECD's VAT Digital Toolkits streamline registration and compliance for non-resident suppliers, such as simplified pay-only regimes.
• Role of Digital Platforms: Platforms can act as tax collectors, leverage data for risk management, and formalize informal sector participation.
• Technological Upgrades: Investments in IT, such as e-invoicing and digital invoicing systems, reduce administrative costs and improve transparency.
• Regional Cooperation: Customs unions (e.g., African, Latin American) can harmonize tax rules, reducing multijurisdictional compliance burdens and fostering economic integration.
• Policy Innovations: Reverse charge mechanisms, withholding taxes, and platform taxation offer ways to address non-resident vendors, while capacity-building efforts by international organizations (e.g., OECD, World Bank) provide technical support.

Recommendations for Developing Countries

1. Adopt Simplified VAT Frameworks: Implement uniform, low-threshold VAT rules for e-commerce to capture informal transactions and reduce evasion.
2. Enhance Digital Platforms: Leverage platforms as intermediaries for tax collection and data sharing, while ensuring robust security and privacy protections.
3. Promote Regional Harmonization: Align tax policies within trade agreements to combat revenue leakage and create a level playing field for local businesses.
4. Invest in Capacity Building: Utilize tools like the OECD VAT Digital Toolkits and secure administrative technical assistance to address constraints in tax administration.
5. Balance Enforcement and Facilitation: Use risk-based auditing, nudging approaches, and taxpayer education to improve compliance without overburdening businesses.
6. Strengthen International Dialogue: Advocate for inclusive global tax reforms, such as pillar 1 of the OECD/G20 initiative, to address digital economy taxation.

Conclusion

Indirect taxation reforms are essential for developing countries to harness the potential of e-commerce and digital trade, ensuring equitable revenue generation while fostering economic growth. The success of these reforms depends on regional collaboration, technological innovation, and sustained capacity building. Prompt action is needed to address current challenges and position developing countries for a sustainable digital future.