The vat treatment of financial services linked to credit cards

Abstract

The treatment of financial services under the VAT has been one of the most contentious VAT issues since the origin of the VAT. Due to theoretical and measurement complexities, most countries opt to exempt financial services under the VAT. Exemption is the cause of all the controversy. Exempting supplies under the VAT compromises one of the corner-stones of the VAT – neutrality.

South Africa is one of many countries that exempts most financial services under VAT. Credit card suppliers in South Africa offer a bundle of financial services comprising fee-based-charges and interest earned. The credit card user is usually only charged for the interest. Interest is an exempt supply under VAT. This gives rise to many distortions for South African credit card users and financial intermediaries.

Exhaustive research has been conducted on the treatment of financial services under the VAT around the world. This study only focusses on the VAT treatment of interest margins of credit cards in South Africa. Firstly, it was determined that credit card offerings in South Africa include bundled offerings which is impractical to separate on a transaction-for-for transaction-basis due to valuation complexities and market conditions. Secondly, it was determined that VAT doesn’t play a major role in credit card suppliers’ decision on how offerings are structured. It is mostly guided by the competition and legislation. Thirdly, it was determined that administrative burden and compliance cost caused by apportionment in South Africa is highly underplayed in the literature. Lastly, it was proposed that full taxation of all financial services with implicit charges at a lower rate or full taxation of fee-based charges with exemption of financial services with a partial input recovery, to be the best alternatives for South Africa to consider to tax financial services under VAT.