- Iman Deschâtres
- 0 Comments
- 4615 Views
A Constantly Moving Target. E-Commerce and Marketplaces: How Tax Shapes Market Access, Growth and Revenue.
Published on 15 September, and already on the bestseller list on Amazon Ireland. I put that down to my Irish friends, and to former colleagues who clearly miss my tax stories. Get your copy on Amazon.
Kazakhstan wants its own marketplaces to pay VAT on foreign sellers’ sales and to switch sellers off on the tax authority’s order. Uzbekistan made foreign sellers of goods register and turned any intermediary in the payment flow into a tax agent. Russia’s Finance Ministry proposes a 22% VAT on cross-border online purchases, collected by marketplaces. Indonesia’s banks started deducting VAT from payments to foreign digital suppliers, and Ghana is collecting at the point of payment too. The EU set a €2 handling fee per product from 1 November, Austria’s €2 parcel tax starts on 1 October and Ukraine voted at the third attempt to tax parcels under €150. And Wisconsin’s Supreme Court left StubHub with a sales tax bill from years before any marketplace law existed.
Here is a glimpse of what caught my attention…and as you read the plethora of changes and consider the challenges they present especially to marketplaces and their sellers, keep in mind that only the right system can enable growth and open new markets without financial or reputational risk. Of course, I note that any observations and comments are solely my own opinion and view, and not intended to be the provision of advice. You should not rely on these without checking with your own tax, legal and financial advisors.
Kazakhstan
A marketplace in Kazakhstan may soon owe VAT on what foreign sellers sell through it.
Draft Tax Code amendments from the Ministry of National Economy make a Kazakh-resident marketplace the VAT payer on a foreign seller’s sales, at 16%, when a foreign company sells goods or electronic services through it to a consumer in Kazakhstan. Today that foreign seller is meant to register and pay the VAT itself, and since 1 January 2026 the tax authority can block the website of a foreign company that ignores its notices. Public comment closed on 25 September. The target date is 1 January 2027.
The same draft gives the platform an enforcement job for all its sellers, not only foreign ones. When a seller ignores certain tax notices, the authority can order its sales suspended, and the marketplace has three working days to comply. Banks and payment organisations will report payments to unregistered foreign internet companies above 100 transactions and 1,000 MRP a quarter.
Uzbekistan
A foreign company selling goods to consumers in Uzbekistan through a marketplace owes VAT from 12 December 2026, and the intermediary handling the payment collects it.
Law ZRU-1173, signed on 10 September, extends to goods a regime that until now covered electronic services. The foreign seller becomes a VAT payer and, if it collects payment itself, has 30 days from its first sale to register, then files through the tax authority’s online account. The place of supply follows the buyer’s residence and delivery address in Uzbekistan.
The test for the platform is the payment flow. Intermediaries that take part directly in the settlements are tax agents: Uzbek marketplace operators, and foreign or local intermediaries acting under commission or agency agreements. A platform that touches the money collects the tax.
Russia
Russia’s Finance Ministry wants marketplaces to collect VAT on what Russians buy online from abroad.
The bill it sent to the government on 24 September makes marketplaces tax agents for 22% VAT on cross-border e-commerce and adds a customs fee of 100 roubles per parcel on goods for personal use under €200, which today enter tax-free.
In March the ministry proposed a ramp: 7% in 2027, 14% in 2028, 22% in 2029. The Industry Ministry had wanted 22% from day one. Reports of the new text give the full 22% from 2027, which suggests the ramp is gone, but platforms are still waiting for detail on timing and mechanics.
Indonesia
Where a foreign digital supplier has not charged Indonesian VAT, the customer’s bank now deducts it.
Since 25 September, state-owned banks and the payment app LinkAja, appointed under Finance Minister Regulation 49/2026, collect VAT at 11/111 of the payment when a customer in Indonesia pays a foreign supplier of digital goods or services, once the system operator confirms the transaction is taxable. The tax authority had announced 10 September; collection started on 25 September. Private banks will join later, and wider coverage depends on the card schemes adapting their systems.
Transactions on which an appointed collector has already charged VAT are outside it. For a platform, being appointed is now the way to keep the bank out of its customers’ payments.
Low Value Goods
Taxation of low-value goods keeps expanding, and it is no longer just VAT: parcel fees are now being added on top.
European Union
From 1 November, every product shipped from outside the EU to an EU consumer is expected to carry a €2 customs handling fee, on top of the €3 duty in force since 1 July.
The Commission set the amount by delegated act on 21 September; it becomes final unless the Council or Parliament objects within 30 days. Like the €3 duty, it is counted per product category in a parcel, not per parcel. Unlike the duty, which covers only parcels worth up to €150, the fee applies whatever the parcel’s value. The duty is due to end on 1 July 2028; the fee is permanent.
The fee is owed by whoever owes the customs duty. Today that is the declarant, and since 1 July the IOSS holder is first in line, which for marketplace sales is usually the marketplace.
Austria
A seller whose Austrian distance sales exceeded €100 million last year pays €2 on every parcel delivered in Austria from 1 October. The tax on parcel deliveries was passed in July. Sales through a marketplace are attributed to the platform, so above the threshold the marketplace pays, even for its smallest sellers. The tax is declared and paid quarterly.
Italy
Italy’s own €2 charge on non-EU parcels worth up to €150, due on 1 October, now starts on 1 December. Decree-Law 162 of 17 September gives it its fourth start date. It is per shipment, collected by customs at import. If both apply, a parcel into Italy carries two €2 charges counted two different ways, plus the €3 duty. The Commission has said national charges like this should end once the EU fee arrives, so Italy’s may never apply.
Ukraine
A foreign marketplace selling to Ukrainian consumers will collect VAT on parcels under €150 from 1 July 2027 at the earliest.
Parliament passed the bill at first reading on 16 September, at the third attempt. Marketplaces and platforms, or their authorised intermediaries, collect 20% VAT through a Ukrainian version of the IOSS. Gifts between individuals under €45 stay exempt. The start is 45 days after the Cabinet certifies the systems are ready, and no earlier than 1 July 2027. The bill and its customs companion both still need a second reading. The reform is a condition of Ukraine’s IMF programme and EU support, and the finance minister said final adoption would bring Ukraine closer to about €4 billion in international funding.
United Arab Emirates
Dubai went the other way. Since 3 August, cross-border e-commerce shipments up to AED 1,000 enter free of customs duty. Dubai Customs says the aim is to cut costs and make the sector more competitive, at a time when Gulf e-commerce overall is shrinking.
Enforcement
United States
A marketplace can owe sales tax on its sellers’ sales from years before any marketplace facilitator law existed.
On 14 September the Wisconsin Supreme Court declined to review StubHub’s case, leaving it with about $8.5 million of sales tax for 2008 to 2013, and as much again in interest and penalties. The Court of Appeals’ test was mechanical: StubHub processed the transaction, charged the buyer, took its fee and paid the balance to the ticket holder. That made it the seller. The court also held that Wisconsin’s 2019 marketplace law only clarified what the old law already required.
In March, South Carolina’s Supreme Court reached the same result for Amazon on a different test. Control over pricing, listings, payments and returns made Amazon “engaged in the business of selling” third-party goods in the first quarter of 2016.
Two courts, two tests, one result: the facilitator laws of 2019 did not wipe out what came before. It is the mirror image of last month’s Tapi Carpets case, where the intermediary won. Any platform that handled payment before those laws should look at where it collected nothing.
Chile
Platforms that pay content creators will report what they paid them. SII Resolution 113 of 31 August creates sworn statement 1965: digital intermediation platforms that handle the money between subscribers and creators report the income of creators with a domicile or residence in Chile, every March, starting in 2027.
European Union
Five years of the e-commerce VAT package have raised €125 billion, €38 billion of it in 2025, from more than 193,000 registered businesses.
Other
- Morocco: Meta will charge 20% VAT on Facebook and Instagram advertising from 1 October for Moroccan accounts with no tax identification number. Advertisers that give one self-account under the reverse charge. TikTok and OpenAI already charge. Same pattern as Azerbaijan last month: the rules date from 2024, and the news is the big platforms applying them.
- Mauritius: from 1 October, the commission a foreign marketplace earns is a taxable digital service. Foreign suppliers register only above MUR 3 million, no longer need a tax representative, and need not register at all if they supply only VAT-registered businesses.
- Poland: from 1 October, joint VAT liability extends to twelve intangible services, advertising, software and IT consulting among them. A buyer paying more than PLN 15,000 on one invoice, or PLN 50,000 a month to one supplier, can be liable for the supplier’s unpaid VAT unless it is paid by split payment. The president signed the law on 4 September.
- Lithuania: the finance minister wants the VAT gap below 9% by 2028, from 13.2% in 2024, with legislation due by mid-October.
- European Union: the Commission’s consultation on VAT and the circular economy, open until 4 November, covers second-hand goods, the destruction of unsold goods and VAT deduction on business cars.
- Canada: provincial place of supply for services depends on the customer’s address, generally the office that hired the supplier. With no address, only an email, it depends on where the supplier performs the work.
- Australia: News Bargaining Incentive enacted on 26 August. Large social media and search platforms with over A$250 million of Australian advertising revenue pay a 2.75% charge on that revenue unless they sign deals with Australian news publishers.
- OECD, Tax Policy Reforms 2026: OECD report. Reviewing 2025 reforms in 92 jurisdictions, it ranks the extension of VAT collection to non-resident suppliers and online platforms among the year’s most significant VAT changes.
Disclaimer: The views, statements or opinions expressed in this article are solely those of the author and do not represent tax advice and are not to be designated to be the views, statements or opinions of any other person, group, association or company.
Image by: MigiasD
Want to know more? Please contact us at contact@deptax.com
