On the Threshold: Smallness and the Value-Added Tax

How to Cite

Satterthwaite, E. A. (2018). On the Threshold: Smallness and the Value-Added Tax. Columbia Journal of Tax Law, 9(2), 177–227. https://doi.org/10.7916/cjtl.v9i2.2862


Value-added taxation (“VAT”) has taken the world by storm. It has been adopted by over 150 countries that comprise about three-quarters of the world’s population, and accounts for more than twenty percent of worldwide tax revenue raised. In some regards, the VAT can be seen as a more modern cousin of the retail sales taxes used by many U.S. states. The U.S. stands out as the only jurisdiction among OECD countries without a VAT, despite recurring calls for adding it as an overdue complement to the income tax. In contrast, in many developing and transitional economies, the adoption of VAT systems as part of austerity measures and fiscal reforms reflects the inexorable pressures of globalization.

Notwithstanding the huge range of country-level experiences with the VAT, its importance is far from waning. The six member states of the Gulf Cooperation Council (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates) are in the process of adopting a community-wide VAT scheduled to take effect in 2018. In early August of 2016, India accomplished what had long been thought to be politically impossible and passed legislation authorizing a national VAT. New Zealand and Australia have recently undertaken a series of VAT reforms to improve their existing VAT systems.[9] Canada’s VAT recently celebrated its twenty-fifth birthday.