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RIFT VALLEY UNIVERSITY BURAYU CAMPUS

FACULTY OF BUSINESS AND SOCIAL SCIENCES


DEPARTMENT OF ACCOUNTING AND FINANCE

CHALLENGES AND OPPORTUNITIES OF VAT ADMINISTRATION IN ETHIOPIAN


REVENUE AND CUSTOM AUTHORITY (THE CASE OF BURAYU CITY
ADMINISTRATION)

A RESEARCH PAPER SUBMITTED TO RIFT VALLEY UNIVERSITY


DEPARTEMNENT OF ACCOUNTING AND FINANCE INPARTIAL FUILLMENT OF
THE REQUIRMENTS BACHELOR OF ARTS DEGREE IN ACCOUNTING AND
FINANCE

GROUP NAME ID.NO

1. GEMECHIS MEKURIA……………………………………………...0035/13
2. EMEBET MARI ……………………………………………................0031/13
3. DADITU DESALE………………………………………………….…
4. GELANE WAKTOLE………………………………………………...
5. MERSHAYE BIRHANU……………………………...........................

ADVISOR: Mr. LAMESA N. (MA)

MAY, 2024
BURAYU, OROMIA
DECLARATION
We declare that the project entitled “Challenges and opportunities of vat administration in
Ethiopian revenue and custom authority (the case of Burayu city administration)” is our
original work and has not been presented for a degree in any other university and that all sources
of material used for the project have been duly acknowledged and we have made it independently
with the close advice and guidance of our advisor Mr.Lamesa Negari (MA).

Student Name ID.No Signature Date

1. Gemechis Mekuria ……………….0035/13 _________ _______


2. Emebet Mari ………………..….....0031/13 _________ _______
3. Daditu Desale…………………….. _________ _______
4. Gelane Waktole…………………… _________ _______
5. Mershaye Birhanu……………….. _________ _______

APPROVAL SHEET

This is to certify that the research paper prepared by Gemechis Mekuria,Emebet Mari,Daditu
Desale,Gelane Waktole and Mershaye Birhanu entitled on the ‘‘Challenges and opportunities of
vat administration in Ethiopian revenue and custom authority (the case of Burayu city
administration)” Submitted in Partial Fulfillment of the requirement for the Degree of Bachelor
of Arts (BA) in Accounting and Finance complies with the regulations and meets the accepted
standards with respect to originally and quality.

Name of Head Department Signature Date


___________________________ ______________ _______________
Name of Advisor Signature Date
___________________________ ______________ _______________
Name of Examiner Signature Date
___________________________ ______________ _______________

I
ACKNOWLEDGEMENT
At the beginning, my all the praise and glory be to the almighty God for his strength, assistance
and encouragement, who enabled us to accomplish our paper despite all the difficulties. This
paper is not only the result of our effort; but also it is the result of the cooperation of many
individuals. First, we are very grateful to Advisor Mr.Lamesa Negari (MA) for his valuable
and irreversible advice, helpful comments and continuous encouragements throughout the study.
We also want to thank all our families for all their continuous help, care and love throughout
our academic career. Last, but not least, we would like to express our powerful gratitude to, all
the employees of Ministry of Revenue Authority in Burayu City Administration for their support
in providing us useful data and necessary information and all individuals contributed their useful
ideas in any way and other persons that helped us to succeed our study.
TABLE OF CONTENTS
DECLARATION ................................................................................................................................................ I
ACKNOWLEDGEMENT ................................................................................................................................... II
LIST OF FIGURE ............................................................................................................................................. VI
LIST OF TABLES ............................................................................................................................................. VI
LIST OF ACRONYMS ..................................................................................................................................... VII
ABSTRACT ................................................................................................................................................... VIII
CHAPTER ONE ............................................................................................................................................... 1
INTRODUCTION ............................................................................................................................................. 1
1.1. Back Ground of the Study ................................................................................................ 1

1.2. Statement of the problem ..................................................................................................... 1

1.3. Objective of the study .......................................................................................................... 2

1.3.1. General objective of the study.................................................................................................... 2


1.3.2. The specific objectives of study .................................................................................................. 2
1.4. Significance of the study ...................................................................................................... 2

1.5. The Purpose of the study ...................................................................................................... 2

1.6. Scope of the study ................................................................................................................ 2

1.7. Limitation of the study ......................................................................................................... 3

1.8 Organization of the paper ...................................................................................................... 3

CHAPTER TWO .............................................................................................................................................. 4


2. LITERATURE REVIEW ................................................................................................................................. 4
2.1 Theoretical perspectives ........................................................................................................ 4

2.1.1 Value added tax (VAT) ...................................................................................................... 4

2.1.2 Sales tax ....................................................................................................................................... 4


2.1.3 Rate of VAT .................................................................................................................................. 4
2.1.3.1. Standard (positive) rate ........................................................................................................... 4
2.1.3.2 Zero Rates ................................................................................................................................. 4
2.2. VAT registration and de-registration in Ethiopian ............................................................... 5

2.2.1 VAT registration ........................................................................................................................... 5

III
2.2.2 De- registration ............................................................................................................................ 5
2.2.3 Effect of non- registration ............................................................................................................ 5
2.3. Principal components of VAT.............................................................................................. 5

2.3.1. Input VAT .................................................................................................................................... 6


2.3.2. Output VAT ................................................................................................................................. 6
2.4. How does VAT differ from Income Tax? ............................................................................ 6

2.5. Why has the tax throughout the world? ............................................................................... 6

2.6. Small trader and setting threshold ........................................................................................ 7

2.7. Implementation of VAT ....................................................................................................... 7

2.8. Impacted VAT on cash flow ................................................................................................ 7

2.9. Records of VAT transaction ................................................................................................. 7

2.10. Arguments toward VAT adoption ...................................................................................... 7

2.11. Tax invoices ....................................................................................................................... 8

2.12. VAT refunds....................................................................................................................... 8

2.13. VAT introduction and administration ................................................................................ 8

2.13.1. VAT introduction ....................................................................................................................... 8


2.13.2 VAT administration .................................................................................................................. 10
2.14. Penalties ........................................................................................................................... 11

2.15. Empirical Review ............................................................................................................. 11

2.15.1 Similar Study in Other Countries.............................................................................................. 12


2.15.2 Studies in Ethiopia.................................................................................................................... 12
2.16. Conceptual Framework .................................................................................................... 13

CHAPTER THREE .......................................................................................................................................... 14


3. RESEARCH DESIGN AND METHODOLOGY ............................................................................................... 14
3.1 Description of study area..................................................................................................... 14

3.2 Research design ................................................................................................................... 16

3.3. Data source and collection method .................................................................................... 16


3.4. Methods of sampling .......................................................................................................... 16

3.5. Methods of data analysis .................................................................................................... 16

CHAPTER FOUR ........................................................................................................................................... 17


4. RESULTS AND DISCUSSION...................................................................................................................... 17
4.1. Background of Respondents............................................................................................... 17

4.2 Responses from the Ministry of Revenue Authority in Burayu City Administration
Employees ................................................................................................................................. 19

CHAPTER FIVE ............................................................................................................................................. 22


5. CONCLUSSION AND RECOMMENDATION ............................................................................................... 22
5.1. Conclusion.......................................................................................................................... 23

5.2. Recommendation ................................................................................................................ 23

REFERENCES ................................................................................................................................................ 24
APPENDIX .................................................................................................................................................... 25

V
LIST OF FIGURE
Figure 1: Cart of Conceptual Framework ..................................................................................... 14

LIST OF TABLES
Table 1: Characteristics of the Respondents Age ....................................................................................... 17
Table 2: Characteristics of the Respondents Sex ........................................................................................ 18
Table 3: Characteristics of the Respondents Educational Level ................................................................. 18
Table 4: Marital status Characteristics of the Respondents ........................................................................ 19
Table 5: Work experience Characteristics of the Respondents ................................................................... 19
Table 6: Do you think that you are giving enough understanding for the society to pay VAT? ................ 19
Table 7: Do you think that the business process in the company is favorable for VAT payer? ................. 20
Table 8: Are value added tax registered report their invoice properly and timely basis? ........................... 20
Table 9: Is the perception of the society is enough about VAT? ................................................................ 20
Table 10: Do you think that there is enough human resource to serve the VAT registered?...................... 21
Table 11: Is there modern equipment to treat the customer in mechanized way? ...................................... 21
Table 12: Is there enough station to serve the VAT payer in a mechanized way? ..................................... 21
Table 13: Is there any way of controlling the VAT register at the time of fraud on VAT payment? ......... 22
LIST OF ACRONYMS

VAT: …………………………….….Value added Tax


ERCA: ……………………….……..Ethiopian Revenue and Customs Authority
FDRE: ………………………….….. Federal Democratic Republics of Ethiopia
HPR: ………………………………..House of People Representative
IMF: …………………………..……International monetary fund
GST: …………………………….….Goods and services tax

VII
ABSTRACT
The study emphasizes on the challenges and opportunities of value added tax in Ethiopian
revenue and custom authority. The major problem in connection with VAT implementation is
whether to perform or not properly perform this newly introduced system value added tax
(VAT) with rule and regulation settled in proclamation 285/2002 by the government. The main
objective of the study was to examine and assess the challenges and opportunities of VAT
administration in ERCA. And also to relate the theoretical aspect of the study with practical
to achieve these objectives, the primary and secondary data were collected using
questionnaires, VAT guide and other ERCA documents. Thus, the sample respondents were
selected using simple random sampling due to homogeneity of the target population. The
collected data were analyzed through descriptive method. The conclusion reveals that, the VAT
registered pay tax properly and timely. However, there are also some others who are not in
the position of doing so. Since there is high level of perception problem regarding the VAT
payment; there is problem of proper and timely payment of VAT. Thus, it is advisable for ERCA
to design different mechanism in order to increase the awareness of the taxpayers. And also,
better to work more in creating awareness regarding VAT in order to change the perception
of the society.

Key Words: Challenges and opportunities, revenue and custom authority, VAT, ERCA,
Burayu city
CHAPTER ONE
INTRODUCTION

1.1. Back Ground of the Study


Value added tax (VAT) is refers to as consumption /expenditure tax charged on the value added
to goods and services by importers, manufacturers and traders at each stages of the production arid
distribution process (Curls, SHOPL 1969). Value added tax (VAT) is also defined as a tax that is
added to the price of goods and services (Oxford Dictionary.2001).

VAT was invented 1954 by a French economist Maurice Laurie who the director of Frances tax
authority. France was the country to introduce VAT effective form April 10, 1954. By 1969, only
eight nations have adopted VAT, out of this, Cote Devour was the first country in Africa County
in Africa to introduce VAT in 1960. Since 1979, VAT has been adopted as the main form of an
indirect tax by many countries in different parts of the world. According to international monetary
fund (IMF) (1944), more than 4 billion, 70% of the world’s population now lives in country with
VAT and VAT raises about $18 trillion in tax revenue, roughly one quarterly of all government
revenue. Currently, among 190 countries of their tax system, and from 53 members of counties of
African Union, 33(60%) have introduced VAT (Abate: 2008).

By understanding the introduction and importance of VAT system, the Federal Democratic
Republics of Ethiopia (FDRE) has adopted VAT in to its tax system in 2003. It has introduced
on January 2003, replacing the former sale tax system. The VAT proclamation number 285/2002
(VAT law has been ratified by the House of People Representative (HPR) six months before VAT
implementation (July, 2002).

1.2. Statement of the problem


VAT is an indirect form of tax, which are assessed and collect from the added value of goods and
service (Abate, 2008).
On January 1, 2003, Ethiopia replaced its sales tax with VAT as standard rates of 15%. The
government also exempts some goods and services from the VAT like medical services, food,
supply of electricity and water post office etc. The government aim of introducing VAT is to
minimize tax avoidance and evasion, faster economic growth and improve the ratio between gross
domestic product and government revenue.

1
The implementation and collection of VAT in Ethiopia has faced different challenges like weak
administration on the tax authority and lack of awareness by VAT payer. These weak
administration and poor awareness by VAT payer will have a direct impact on the government
administration.

1.3. Objective of the study


1.3.1. General objective of the study
The general objective of the study is to assess the challenges and opportunity of VAT
Administration in Ethiopia Revenue and Customs Authority (ERCA) in Burayu city
Administration.
1.3.2. The specific objectives of study
• To examine the challenge faced by the tax authority in VAT administration in Burayu City
Administration.
• To identify the problem faced by VAT payers to comply with the VAT law from view of
administrating body in Burayu City Administration.

1.4. Significance of the study


The study would be useful for the tax authority to improve its tax administration by overcoming
its challenges and by digging out its opportunities for improvements based on the recommendation.
Additionally, this study would have a paramount significance for further researcher by being as a
reference.

1.5. The Purpose of the study


VAT registration helps to raise the government revenues without punishing the wealthy by
charging them more through an income tax.
VAT registration can enhance a business’s credibility with customers, suppliers and financial
institutions and also crucial requirement for a business to comply with tax laws.

1.6. Scope of the study


Due to constraint in money, time, and experience, the scope of the study was limited to the
assessment of the challenges and opportunities of VAT administration in Ethiopian Revenue and
Custom Authority (ERCA) in Burayu City.
1.7. Limitation of the study
The researcher has faced some problems while conducting the study such as; Lack of experience,
Unavailability of newly published references and unwillingness of some respondents to return
questionnaires on time.
The data might biased due to misunderstanding of the respondents during data collection process.
Time and financial problems may also affect the feasibility of the study. In addition to the above
problems, the unavailability of the respondents at the required time may also have impact on the
study.
The loss of some relevant data while collecting the data may also have impact on the feasibility of
the study.

1.8 Organization of the paper


The paper would contain five chapters. In the first chapter includes the background, statement of
the problem, objective of the study, significance of the study, the purpose of the study and scope
of the study. In the second chapter the literature review, in the third chapter methodology of the
study, in the fourth chapter the data presentation and analysis, in fifth chapter summary of finding,
and summary of reference.

3
CHAPTER TWO
2. LITERATURE REVIEW

2.1 Theoretical perspectives

2.1.1 Value added tax (VAT)


VAT is a tax levied on the increase in value of commodity that has been created by the taxpayer’s
stage of the production or distribution cycle. It is a sales tax based on the increase in value or price of
the product at each stage in its manufacture and distribution. The cost of the tax is added to the final
price and is eventually paid by the consumer (Harrison and Krelove 2005). "VAT" - value added tax
- has spread throughout the world since its introduction in 1955. France is credited with first
implementing VAT. It did so in 1955. The tax spread through Europe, South America and parts of
Africa in the 1960s and 1970s before taking a hold in other regions. Today, it is a key source of
government revenue in more than 130 countries. About 70 percent of the world’s populations now
live in countries with a VAT (Keen & Wood, 2007).
2.1.2 Sales tax
The tax is computed as a Percentage of the total sales price. Sales tax may be imposed on the purchaser
or on the seller; in the former case they are charged on each transaction and in the latter they are
collected as a percentage of the gross receipts during a given period. A sales tax also can be imposed
at more than one but less than all levels of production or distribution. (ERCA, Annual Bulletin 2014)
2.1.3 Rate of VAT
The VAT rates applicable to taxable goods and service differ from country to country. Some
countries have adopted VAT with a single rate and other with a multiple rate (more than one rate).
Some country also use VAT inclusive price and some other country adopted VAT exclusive rate.
In general, there are two types of VAT rates to charge taxable supplies (Bhatia: 2003).
2.1.3.1. Standard (positive) rate
Standard rate is a positive VAT rate (>0%) set by a country‘s tax laws to charger VAT on taxable
goods and service.
2.1.3.2 Zero Rates
Zero rates are a VAT of zero. This means a taxable person charges VAT at 0% on its sales. Hence,
the taxable supplier does not have tax ability on its sales but is allowed the credit (refund) for tax
paid on its purchase to provide the supply.
2.2. VAT registration and de-registration in Ethiopian
2.2.1 VAT registration
A person is obliged by law to register if the business is likely to have taxable turnover (gross sale
excluding tax) in 12 month excluding birr 500,000.
The turnover is calculated on an ongoing basic. Two period need to be sided the past 12 calendar
months and 12 calendar months on a month by month basics. There is the need to estimate of the
end of each trading calendars month the total value of taxable goods and services supplied by all
the businesses for the past 12 month. Where the total exceeds birr 500,000 than there is the
requirement to register for VAT. A person may voluntarily apply for registration even if his
turnover is below birr 500000 supplies or business activities if the person regularly rendered at
least 75% of his goods and service to registered persons.
Voluntary application for VAT registration cannot necessary results in acceptance by the tax
authority. A VAT registered person is required to keep record for all state and purchased made and
received a summary of VAT for each period covered by the VAT returns. This record is called a
VAT account.
2.2.2 De- registration
A person who has registered for VAT may cancel his/her name by making arrangement with
ERCA/VAT officials. The reason for de–registration may be; if the business ceases trading
permanently, if the business is sold, when the value of taxable supplies falls consistently below
the VAT registration thresholds, if he /she have been registered in error or he/she has ceased to be
a taxable person, etc.
2.2.3 Effect of non- registration

A person who is require to registered to register for the VAT is a ‘’taxable person’’ who is subject
to the duty to impose and collect VAT on all supplier whether or not the person is registered. It is
important that the low make this clerk and not excluded a person from the scope of the low just
because of a failure (deliberate or otherwise) on the part of the person to apply for registration.

2.3. Principal components of VAT


Two principle component of VAT these are input VAT and output VAT (Abate: 2008).

5
2.3.1. Input VAT
Input VAT is the VAT payable by a taxable person on goods and services supplied to him and on
goods which he imports for the purpose of a business carried on by him and which registered for
VAT. Viewing the concept from the other angel, it is the VAT payable on purchase on taxable
supply including capital goods and operating and advertisement expenditures.
2.3.2. Output VAT
Output VAT is the VAT collectable by a taxable person at the time of sale of taxable goods and
services (supply). It is the VAT chargeable on sales of taxable goods and service whenever a
taxable person supplies taxable goods or services to other person. VAT must be included in the
price charged for those taxable goods or service. This is output VAT for the supplier. Output VAT
is not a component of the sales price rather it is a liability to the taxable person which is collected
on behalf of the tax authority.

The logic of VAT is that during a VAT accounting period, a VAT reregistered person pays VAT
on its purchase, which is called input VAT, and the person charges VAT on its sales, which is
called output VAT. At the end of the VAT accounting period, the difference between the amount
of output tax and input tax represents either VAT payable to the tax authority or VAT refundable
from the tax authority.

2.4. How does VAT differ from Income Tax?


The costs of the tax born by VAT are exampled institutions and unregistered customer. Obviously,
the later consumer more, so that VAT primarily tax’s the non-business and consumer. In
comparison, income tax applies across all spectrums of the community.

2.5. Why has the tax throughout the world?


Economic theory has been center to the spread of the tax throughout the world. Economic theory
charged its assessment of VAT through the 20th century to greatly over simplify (Bhatia, 2003).
Up to 1950, there was regarded as undesirable because of it discriminated in the market place via
influencing consumers decisions. Economist during these period assumed in direct tax would tax
commodities at different rates.
2.6. Small trader and setting threshold
The VAT tends to impose high compliance cost on small trader who generally does not have
sufficient resources its keep proper record of their transaction and it comply with accounting rule.
Setting threshold is complex, however some countries recognize that the below threshold and
hence exempted business bear the burden of the tax on their input purchase and thus allow them
to register voluntary. Firms in middle stage or selling zero rated goods/ services have strong
incentive texperience2l00abuletaion in the VAT net in order to be entitled to claim for their tax
credit.

2.7. Implementation of VAT


The VAT due on a taxable person (VAT registered person) is entitled to deduct all the tax already
paid at the proceeding stage. Therefore, double taxation is avoided and tax is paid only on the
value added (incremental value) at each stage of production and distribution.

2.8. Impacted VAT on cash flow


One has to take case full timing and sales of taxable supplies otherwise VAT will affected his /her
cash flow. If VAT registered person purchase more cash out flow, which results in financial drain
on the business.

2.9. Records of VAT transaction


VAT is a modern tax system it is expected to modernize the VAT administration for the following
reason: VAT force enterprises to have their own book of their account would help the hole tax
system to have a clear knowledge about taxable transaction and income change this would certainly
encourage the VAT payers not to way another for each VAT transaction take place (Abate; 2008).

2.10. Arguments toward VAT adoption


There are several argument for or at against the adoption of VAT in Ethiopia based on its strength
and weakness.
Some arguments are advanced for the adoption of VAT first, VAT has a broad base. So it would
provide with the higher and constant source of revenue for the government. Second, VAT
promotes saving and investment in consumption type of VAT the investment and saving are
excluded from the tax base, capital, formation is promoted. Third, VAT would reduce tax evasion.

7
As per the principal of taxation (Abudulahmit; 2002), a person should be taxed only accounting to
his /her ability to pay, but it is in congruent with this principle because poor person soon pay higher
percentage of their income for the level of consumption they have a number countries have,
however exempted basic necessities particularly food item from vat in order to compensate for its
regressive effects time of introducing VAT.

2.11. Tax invoices


As to the ministry or revenue website, the Ethiopian VAT based on the invoice credit method in
which tax payer are given credit for the VAT paid on inputs when it is supported by proper invoice
and importer declaration.

2.12. VAT refunds


There are two main provisions in the legislation concerning VAT refunds. The first provision is
for registered tax payers who have at least 25% of the value added of their taxable transaction for
the accounting period, other than zero rating of the disposal of a going concern, fixed at authority
to make a cash funds of the amount of the VAT applied as a credit in excess of the amount of VAT
charged for the accounting period with in a period of two months after the registered person files
an application for refunding, accompanied by documentary proof of payment of the excess amount
(ERCA;2003).
In both the above cases, when the tax authority is satisfied that a person who made an application
for refund has over paid VAT, the authority is allowed first to apply the amount of the excess in
the reduction of any tax levy, interest or penalty payable by the person under the VAT
proclamation, the customs proclamation, income tax proclamation, or the sales, and excise taxes
proclamation, the tax authority is required to reply any amount remaining to the person (Gebrie;
2006).

2.13. VAT introduction and administration


2.13.1. VAT introduction
The problem of introducing a VAT depend on a large measure on whether the countries have had
previous experience with general sales taxes, the nature of the taxes that the VAT will replace, the
effectiveness of tax administration, the lead time and how the VAT is structured in teams of rate,
exemptions and treatment of small tax payers (John ;1973).
A. Publicity and tax payer’s information

It is important that tax payer should fully understand the vat rate would apply only on their value
added. Ignorance may lead the public to accept price increase false fully attributed to VAT without
question. The important requirement of the successful introduction of VAT is an adequate
publicity campaign aimed at both taxpayers and consumers Argentina, Korea, Columbia, Mexico
and Indonesia were all engaged in substantial campaign of VAT well before the final decision to
adopt the tax was made (Jhon;1973).In order to despite some of the general worries, a services of
articles, questions and answer session, feature stories and lecture, seminars conferences and
meeting were made in Korea on VAT in addition to daily newspaper, TV and radio (Han,1987).
B. Lead-in-time
Enough lead-in-time should be allowed to permit careful preparation of regulation, in turn reform
and system for registration taxpayers and processing VAT return and payment. Chile was able to
reduce the lead-in-time a few months because of prior experience with turnover tax (Jan tsces,
1987). In addition, Zambia has launched successes fully within a short period of 9 month time
(Edward, unpublished) And Korea and exerted on filling tax reform before the actual
implementation of VAT during 1977(Han,1987).
C. organizational issue
Major decisions that must be taken before introducing a VAT are the choice of organization to
administer the tax and organizational changes required by the introduction. VAT nearly all
developing countries that apply a VAT through retails stage have assigned its administration to the
same organization that administers income taxation usually also administer the taxes that the VAT
replace. Some developing countries have considered establishing a separate organization to
administer VAT (Jan Satchel, 1987). For example, Zambia has organized a separate VAT
department to administer VAT (Jhon; 1973)
D. Staffing requirement and training

Most developing countries have had to retain their staff to administer the tax. Given the resource
constraints faced by tax administration in developing countries most of them have conducted
adequate training program. Where training has been in adequate, the tax payer’s resistance to the
tax intended to increase (Murphy and Higgins).

9
2.13.2 VAT administration
Identifying tax payers processing returns, collecting collection ,making refunds, auditing tax
payers, and levying penalties the main tasks must be performed by the organization in charge of
VAT. Tax payers must apply with invoicing and booking requirements in addition of filling
reforms and paying the tax (Bhatia; 2003).
A. Tax payers’ identification
Developing countries have approach registration for VAT in a variety ways. In countries in which
a sales tax through their retail stage that was in force before VAT, tax payers usually were not
required to register again and use old identification numbers. In counters were the pervious sales
tax did not extend to the retail state, all tax payers have been required to register for VAT (Murphy
and Higgins).
Under foreman VAT system, any person who wishes to starts a business must register with the
distinct tax office within 20 days from the date of decrement. Then the district tax office will issue
a traders registration certificate within 7 days of receiving an application (Murphy and Higgins).
B. Invoicing and bookkeeping requirement
Most developing countries require some form of invoicing for all transactions on which VAT is
charged, including sales to final consumers. To encourage consumer to request invoice, a few Latin
American government hold lotteries in which invoices are the tickets.
C. Filling and payments requirement
Regular VAT taxpayers are required to fill and pay tax monthly, however; in the time of inflation
the period may be reduced to be monthly. In Zambia, all registered supplies are required to ledge
a VAT return within 21 days after the end of the relevant tax period (Edward, unpublished)

Few developing countries, however, use computers effectively to detect taxpayers that stop filling
VAT return (John; 1973).

D. Audit of VAT
The initial literature to VAT tensed to minimize administrative difficulties by emphasizing the
bulletin chalking mechanisms of the tax. The considerable evasion of VAT existing in developing
countries methods used to evade VAT include, among others
Under reporting of sales, abuse of the credit mechanism (which may invoice the use of false
invoices) and fraud tent refund claims (Jantscher, 1987).
Developing countries that have enforced VAT most successfully have opted or audit method that
call for checking a few selecting item among as large a number of taxpayers as possible
(Jhon;1973).
According to Edward (unpublished) Zambia VAT office has different type of inspection or visits.
Firstly, normal control visit that is carried out by two officers on higher risk areas in turnover
compliance.

In addition to examining taxpayer’s records several countries enforce control of VAT by checking
inventories of goods on hand and inspecting merchandise in shops, warehouses, store rooms and
other business promise (Jhon;1973).

E. cost of administration
The cost of administration of a VAT in developing countries usually ranges between one and the
two percent of collect. But low collection cost mean that the administration is concentrating
executively on the largest taxpayers and neglecting the others rather than efficiently (Jantscher,
1982). In Ethiopia, FIRA spends only 0.0025% of revenue for tax collection. This low expense
does not always translate in efficiency (Tax low design; 1996).

2.14. Penalties
Penalties for international and server tax evasion and tax payer noncompliance with the tax lows
are a common tax administration practice in the world. Nonetheless, the types of penalties imposed
for violation of VAT legislation differ from country to country. Some countries send violators
directly to others temporarily close the tax payer’s business premises. Some levy stringent fines
for failure to register and to fill return on time.
In the Ethiopia case, according to articles 45-47, administrative penalties are imposed while
business are not registered for VAT where registration is required, where any person issued
incorrect tax invoice, where invoice are issued without being registered, where there is
underpayment and late filling of returns.

2.15. Empirical Review


In this section, the empirical studies focus on prior academic researchers concerning the Problems
Related to Implementation of Value Added Tax in on revenue generation. Accordingly, the

11
following studied papers were selected from other countries and from Ethiopia to show the
findings and the recommendations that are related to this study.

2.15.1 Similar Study in Other Countries


VAT has spread throughout the world since its introduction in 1955. Its format has changed and
now incorporates what was once an offshoot, "GST" (goods and services tax). France is credited
with first implementing VAT. It did so in 1955. The tax spread through Europe, South America
and parts of Africa in the 1960s and 1970s before taking a hold in other regions. For example, the
tax spread throughout the South East Asia/Pacific region from 1984 (Indonesia) to 1999
(Australia).Today most countries throughout the world have the tax. All members of the OECD
and all leading economies in the world have a VAT (or very broadly comparable tax), apart from
the US. For most of the twentieth century, the principal federal tax on individuals in the United
States has been on income, whether it is earned from labor (wages and salaries) or capital (interest,
dividends, and capital gains). But a growing number of economists and politicians have concluded
that the United States should replace the income tax-partially or entirely- with a tax on
consumption. Most of the political debate over a consumption tax has centered on whether the
United States should adopt a value-added tax (VAT) similar to the ones that European countries
have. While a VAT definitely is a tax on consumption, it is not the kind that most consumption,
tax advocate prefer. What’s more, the debate over whether to add a VAT to the U.S. tax code has
obscured the more basic issue of whether to tax income or consumption. (Richard, 2005).The
determinants of tax revenue shares and constructed an index of tax effort for the 16 Arab countries.
The results submit that the main determinants of the tax share in the GDP for the Arab countries
are the per capita income, the share of agriculture in GDP and the share of mining in GDP. These
variables are statistically significant and possessed the expected signs. Further variables that are
also important determinants are the share of exports and imports and in only the non-oil Arab
countries, the outstanding foreign debt was found significant and positively related to the tax share.
(Eltony, 2002)

2.15.2 Studies in Ethiopia


In Ethiopia there are some studies done on Problems Related to Implementation of Value Added Tax
in on Revenue Generation. Among these some of them are reviewed as follows: On the title “The Role
of Value Added Tax on Economic Growth of Ethiopia’’, the objective of the researcher was to analyze
the role of VAT on economic growth of Ethiopia using the data from 2003 to 2012 based on theoretical
and empirical evidences. To meet his objective, he used time series macro-economic data on GDP
using VAT, total tax revenue excluding VAT, non-tax revenue and foreign revenue as independent
variables. He employed Descriptive statistics and multiple regressions to analyze the data. The finding
of the study reveals that as compared to sales tax, VAT boosts the general economic growth of Ethiopia
but the issue of regressively resembling to sales tax still continues. During the periods under review,
the growth rate of VAT was 66.27% on average. For the periods of sales tax, the average growth rates
of GDP were only 2.53%. However after executions of VAT, such growth rate reached about 21.9%
on average. The analysis also showed as the average ratio of VAT to GDP becomes 2.95%. The finding
also reveals that, VAT, total tax revenue and non-tax revenue except foreign revenue were significant
at 5% level of significance but all of them positively contributed for economic growth during the
periods under review. However, to be effective, it requires strong administrations and cooperation of
the tax payers with taxing authority and the government in general. (Dasalegn, 2014)
On the title the effect of value added tax on revenue generation in the ministry of revenue eastern Addis
Ababa branch office, the objective of the researchers was to analyze effect of value added tax on
revenue generation, her results showed that majority of tax payers and employees were 27 given
awareness about the context and importance of Value Added Tax in their town. However, the results
indicate that some employees and tax payers / Value Added Tax registered/ did not get the awareness
in advance. This shows that there is a high gap in understanding the attitude of the taxpayers between
themselves and the tax officers. The main challenge in the Value Added Tax administration process is
the attitude of the taxpayers. Both the taxpayers and tax officers reported that there are attitudinal
problems and the observation of the researcher also reveals this fact. Hence, giving all the necessary
information to the taxpayers using appropriate methods needs due attention. (Taye, 2017)

2.16. Conceptual Framework


As a result of the theoretical and empirical reviewed above; the study has developed the following
schematic representation of the conceptual framework. This conceptual framework describes the
relationship of tax revenue with Infrastructure, Material unavailability, integration of stakeholder,
quality and quantity of ministry employee, regulation, and stakeholder involvement.

Awareness

Infrastructure
Integration
13
VAT
VAT
REVENUES
Tax
evasion
Regulation
Tax
Time
Audit

Source: Adopted from different literatures

Figure 1: Cart of Conceptual Framework

CHAPTER THREE
3. RESEARCH DESIGN AND METHODOLOGY

3.1 Description of study area

The study will be conducted in Oromia regional state of Burayu Oromia Special Zone. Burayu is
one of the cities found in Oromia Regional State in Ethiopia. The city is found 10km far from
Finfinne (Addis Ababa) the capital of Oromia Regional state, Ethiopia, and Africa, on the main
road from Finfinne-Ambo-Nekemte-Asosa on the west ward. It is a major living area for nations,
nationalities and peoples. It is divided into six (6) kebeles. These kebeles are: GafarsaBurayu,
Lakku Katta, Malka Gafarsa, Gafarsa Nonno, Gafarsa Gujjee and Burayu Kata. Burayu shared
border with different cities and woredas. On the west direction, Walmara woredas, Sululta city
from North, on the South Sabbata Hawasworeda, and Finfinne from East. The total area of the city
was 9057 hectares. However, the number of population is increasing dramatically. In the year 1977
only 4138 people lived in the area. But, in the 1999 this number increased dramatically to 63,873.
Now more than 334,797 peoples live in the city (Burayu Communication affairs Bureau,
2019).This Oromia Special zone is located in western part of Ethiopia which is demarked by
administrative boundary from the capital city of Ethiopia, Addis Ababa. Burayyu ,Oromia Special
zone Before people settled in Burayu, the place was covered by big forest. As the number of people
increased they expanded to find the farm land, the forest was cleaned. Burayu was founded in 1946
by the land lord and governor of the area Girazmach Roobii Kallacha. In the late 18th c Burayu
and the area was conquered by Oromo Tulama called Gosa Gulale (Gulalae Clan). The clan formed
the system called Gada system around the area called Qachare to rule themselves (Burayu
Communication Bureau, 2019). The name “Buraayuu” named from the black tree called
“Burayuu” found in that area in the ancient time. Traders come to Finfinnee (Addis Ababa) from
Wallaga, Jibaat, Gindabarat, and Mugar to take rest and meet each other under this black tree
(ibid). According to the information from Burayu Communication affairs Bureau (2019) the
Institutions in the city include: Number of government sections 31, Number of non-government
sections 9, Number of Federal government sections 16, Number of oil centers 6. The Populations
size, density and distribution of Burayu city is that the Number of total population: Male=199,013
and Female 176,336, grand total is 375,349. Density: in one kareemeter square 0.011 peoples
living and the Number of peoples by religions: Orthodox=35%, Muslim=25 %, Waqefata=4%,
Protestant=36% according to data obtained from Burayu Communication affairs Bureau (2019)
Burayu city is found 2450-2600 above sea levels. The city has two historical places: Anfoo and
Irreecha Malka Atete and five (5) tourist sites including these two historical places, Gafarsa Dam,
Dire Gujee, Galiima Anfoo and Kolobo forest (ibid). Regarding the peace and security of the
society in city was given priority first for peace and supporting the peace keeping by their power,
wealth and money. Different social class: Qerro`s, Aba Gada`s, Elders, religion fathers, women’s,
and investors are working together when any peace and security problem happened in the city.
Also, the city was a village for different youth came from different Oromia zones, which make the
city to have high number of youth more than city capacity. As these youth are unemployed, it was
very dangerous for security. / has a latitude and longitude of 8°9'N35°31 'E and an elevation of

15
2085 meters. This town has an estimated total population of 36,563 of whom 1 8,837 are men and
1 7,726 are women; 23.97% of its population are urban dwellers and 76.023% are rural dwellers.
In this town there are 13469 house hold. Burayu is known for its factory. During the 1960s,
experimental factor were started around in the Burayu 1960s.

3.2 Research design

The study under consideration would attempt to apply the descriptive research design and various
data collection methods which would be suitable for successful accomplishment of the descriptive
research.

Both qualitative and quantitative data analysis techniques were employed to analyze the data
collected from primary and secondary sources.
The qualitative data analysis was applied to explore prospects and identify major problems
observed in implementing and administering VAT. While quantitative data analysis was made for
comparative analysis in assessing the relevance of practice of VAT in relation to the content of
Ethiopian VAT law.

3.3. Data source and collection method


The researcher uses both primary and secondary source of data in order to collect /gather/
necessary information regarding subject of the study. The primary data would be collected from
employees of Ethiopian Revenue and Custom Authority of Burayu City through distribution of
questionnaires. Secondary data would be extracted from different books, relevant documents,
journals and articles, organizational manuals and different websites.

3.4. Methods of sampling


The target population of the study would be employees of Ethiopian Revenue and Custom
Authority (ERCA) of Burayu City. The total number of employees working in the organization
are 30 (statistics and information center of the organization) as on January 2015. The researcher
takes all of them because it is very small size.

3.5. Methods of data analysis


The data would be analyzed by using descriptive analysis through tabulation and percentage. And
also the data obtained would presented by explanation and interpretation.
CHAPTER FOUR
4. RESULTS AND DISCUSSION
In this study, data were collected by the researcher. data was collected by use of questionnaires
presents data collected from 30 from ERCA’s office Burayu City by analyzing official documents
and by past records inferences.
4.1. Background of Respondents
Table 1: Characteristics of the Respondents Age

Age Frequency Percent


18-20 0 0%
21-50 85 98.8%
Above 51 1 1.2%

17
Total 86 100%
Source: own survey (2023)

Regarding the respondent’s age, Table 1 above shows that out of the 30 respondents 0% (0) are
18-20 years old, 100%() respondents are 20-50 years old, and 0% (0) Above 51 years old. This
implies that all of the respondent’s age ranges between 20-50 years. it indicate the ministry has
productive manpower to detect any evasion fraud that happen from the tax payer and it questioned
the tax office poor vat administration capacity.

Table 2: Characteristics of the Respondents Sex

Gender No/ Percent


Male 62 72%
Female 24 28%
Total 86 100%
Source: own survey (2023)

Regarding the respondent’s Gender, Table 2 above shows that out of the 86 respondents, 62
respondents (72%) are male, 24 respondents (28%) are female. This implies that the majority of
the respondents are male.

Table 3: Characteristics of the Respondents Educational Level

Educational Level Frequency Percent


Master 12 14%
Degree 74 86%
Diploma 0 0%
Total 86 100%
Source: own survey (2023)

As indicated table 3 Moreover, educational level of the respondents was also studied and results
show that out of the 86 respondents, 74(86%) are Degree, 12(14%) Master this shows that all the
respondents are qualified enough to easily understands and respond the questioners correctly. The
ministry should encourage those employees who want to follow for masters or above in order to
increase the number of qualified employee.

Table 4: Marital status Characteristics of the Respondents


Marital status Frequency Percent
Single 49 57%
Married 36 42.8%
Divorce 1 1.2%
Total 86 100%
Source: own survey (2023)

Concerning the respondent’s marital status, Table 4. above shows that out of the 86 respondents,
49 respondents (57%) are single; 36 respondents (42.8%) are married and 1 respondant (1.2%) are
divorce. This implies that the majority of the respondents are single.
Table 5: Work experience Characteristics of the Respondents
Work experience Frequency Percent
2-5 40 46.5%
6-10 43 50%
11-15 2 2.3%
16-20 1 1.2%
Above 20 _ _
Total 86 100%

Source: own survey (2023)

Regarding the respondent’s year of experience in the specific field, Table 5 above shows that out
of the 86 respondents 46%(40)have 2-5 year of experience, 50%(43) respondents have 6-10 year
of experience, 2.3% (2) respondents have 11-15 years of experience, 1.2% (1) respondents have
16-20 years of experience. This implies that the majority of the respondents have medium year of
experience of work experience in the ministry revenue. it indicate the ministry lack of experienced
manpower to detect any evasion fraud that happen from the tax payer and it questioned the tax
office poor vat administration capacity.

4.2 Responses from the Ministry of Revenue Authority in Burayu City


Administration Employees
Table 6: Do you think that you are giving enough understanding for the society to pay
VAT?

19
Choose Frequency Percent
Yes 39 45%
No 47 55%
Total 86 100%
Source: own survey (2023)

Regarding weather, they are giving enough understanding for the society to pay tax, Table .6 above
shows that out of the 86 respondents, 47 respondents (55%) does not give enough understanding
to the society, 39 respondents (45%) are giving enough understanding to the society. This implies
that the majority of the respondents has not giving enough understanding for the society to pat tax.
This indicates that, the majority of the society has no enough understanding about paying VAT.

Table 7: Do you think that the business process in the company is favorable for VAT
payer?

Choose Frequency Percent


Yes 28 93.33%
No 2 6.6666%
Total 30 100%
Source: own survey (2023)

Regarding weather, they think that the business process in the company is favorable for VAT
payer, Table 7 above shows that out of the 30 respondents, 28 respondents (93.33%) choose
“yes”. 2 respondents (6.66%) choose “No”. This implies that the business process in the
company is favorable for majority of VAT payer.

Table 8: Are value added tax registered report their invoice properly and timely basis?

Choose Frequency Percent


Yes 27 90%
No 3 10%
Total 30 100%
Source: own survey (2023)

Regarding weather, value added tax registered report their invoice properly and timely basis,
Table.8 above shows that out of the 30 respondents, 27 respondents (90%) choose “yes”. 3
respondents (10%) choose “No”. This implies that the majority of value added tax registered report
their invoice properly and timely basis.

Table 9: Is the perception of the society is enough about VAT?

Choose Frequency Percent


Yes 7 3.33%
No 79 96.66%
Total 86 100%
Source: own survey (2023)

Regarding weather, the perception of the society is enough about VAT. Table.9 above shows
that out of the 30 respondents, 29 respondents (96.66%) choose “No”. 1 respondent (3.33%)
choose “Yes”. This implies that the majority of the society’s perception is not enough about
VAT.

Table 10: Do you think that there is enough human resource to serve the VAT registered?

Choose Frequency Percent


Yes 11 3.33%
No 75 96.66%
Total 86 100%
Source: own survey (2023)

Regarding weather, they think that there is enough human resource to serve the VAT registered.
Table 10 above shows that out of the 30 respondents, 29 respondents (96.66%) choose “No”. one
respondent (3.33%) choose “Yes”. This implies that the human resource is not enough to serve the
VAT registered.

Table 11: Is there modern equipment to treat the customer in mechanized way?

Choose Frequency Percent


Yes - -
No 86 100%
Total 86 100%
Source: own survey (2023)

Regarding weather, there is modern equipment to treat the customer in mechanized way. Table 11
above shows that out of the 86 respondents, 86 respondents (100%) choose “No”. zero respondents
(0%) choose “Yes”. This implies that there is no modern equipment to treat the customer in
mechanized way.

Table 12: Is there enough station to serve the VAT payer in a mechanized way?

Choose Frequency Percent


Yes 15 16.66%
No 71 83.33%
Total 86 100%

21
Source: own survey (2023)

Regarding weather, there is enough station to serve the VAT payer in a mechanized way. Table 12
above shows that out of the 30 respondents, 25 respondents (83.33%) choose “No”. five
respondents (16.66%) choose “Yes”. This implies that there no enough station to serve the VAT
payer in a mechanized way.

Table 13: Is there any way of controlling the VAT register at the time of fraud on VAT
payment?

Choose Frequency Percent


Yes 61 86.665
No 25 13.33%

Total 86 100%

Source: own survey (2023)

Regarding weather, there is any way of controlling the VAT register at the time of fraud on VAT
payment.

CHAPTER FIVE
5. CONCLUSSION AND RECOMMENDATION
The main objectives of this research are to investigate challenges of VAT administration in
Ethiopian revenues and customs authority under Burayu branch office. In reaching to the
conclusion and recommendation both the taxpayers and the revenue authority officials were asked
with structured and semi structured questionnaires to investigate the existing
problem of the tax administration of the selected officers of Authority. Based on the presentation
and analysis of the data obtained, conclusions and recommendations drawn are discussed in this
chapter.
5.1. Conclusion
According to findings of this study, taxpayers encounter different problems. Among the major
factors influencing taxpayers perceived VAT Administration include complex tax system,
cultural background, awareness and compliance. According to perceived level of VAT
Administration, about seventy five percent of relative response of taxpayers to overall perceived
VAT administration measure was not satisfactory. This could lead to poor actual VAT
Administration problem. On average, complex tax system, cultural background, awareness and
compliance are those relative factors studied in this research. These have significant effect on
VAT Administration, reduce government income and hinder country’s development progress in
general.
It was found that having less experience in a given business has visible effect on VAT
Administration. Complex tax system has positive and significant impact in influencing VAT
Administration. Another important factor contributing to VAT Administration is the capacity of
the authority to investigate tax system. Capability of authority to investigate actual taxable
income or improving chance of detection, significantly affect VAT Administration.
Awareness of taxpayers regarding why the citizen pays tax also impact VAT Administration.
Positive perception of the citizen to pay tax also affects VAT Administration. Contrarily, weak
follow up has no significant impact. Cultural backgrounds of taxpayers have significant impact
on VAT Administration

5.2. Recommendation
Based on the findings, this study suggest to Ethiopian revenues and customs authority, Burayu
branch office, the following issues to mitigate the problems associated with VAT
administration. Since having less experience in a given business has visible effect on VAT
Administration, the authority/government has to give attention less experienced VAT registered
organization and support them in different aspect. Because of complex tax system has positive and
significant impact on VAT Administration, the authority has to improve its capability to enhance
VAT Administration level. With regard to awareness, the tax authority of ERCA Burayu branch
office has to give updated and proper awareness on VAT Administration with its benefits and
related consequence. Hence, if the authority puts some enforcement and properly follow on the
simplicity of tax system it can easily improve VAT Administration. The role of tax awareness and

23
perception of tax payers towards the tax system is pivotal for voluntary VAT Administration
decision; hence, the Ethiopian Revenue and Customs authority Burayu branch office should
continuously work on tax payer’s awareness creation and tax knowledge by giving adequate tax
training and education to tax payers especially by giving clear feedback for taxpayers. The ERCA
shall provide continuous problem solving and practical trainings to tax payers by using media such
as Television, Radio, and Newspaper etc... and by arranging training sessions through integration
with universities. It is also recommendable to incorporate tax course in educational curriculums as
a common course just to create tax awareness to citizens. ERCA should also encourage devoted or
committed employee through different mechanisms such as by giving recognition for them, by
giving some additional incentive; this will ultimately encourage VAT Administration. Government
should ensure accountable and transparent so that taxpayers are willing to pay tax and understand
its outcome. Unless taxpayers understand the result of their contribution to pay tax, they are not
willing to register to VAT. Particularly, Burayu revenue office has to give training to the whole
society starting from elementary school in the form of education. Burayu revenue office should
carry out monthly and quarterly monitoring and evaluation and the reports should be well analyzed
for continuous improvement. Burayu revenue.

REFERENCES
Abate, M.T, (2008): Ethiopian tax accounting: principles and practice A.A
Fjeldstad, O and ranker, L. (2003).taxation and tax reforms in developing
countries.8thedition: illustration from sub-Saharan Africa, Bergon, Norway: Chr. Michelan
Institute.
HL Bhatia, (2003). Public finance 24th revised edition: New Delhi.
Gebrie Worku, (2006). Ethiopia tax accounting theory and practice 2nd edition: Finfinne, Alem
printing press.
John Winfrey, (1973). Public finance and taxation 5th edition: U.S.A.
MisrakTesfaye, (2008) Ethiopia tax accounting theory and practice 1stedition: Finfinne, Mega
printing press.
Murphy Higgins, (2001) Concept in Federal Taxation. 1stedition: Stanford University
Victor Thuronyi (1996). Tax design and drafting; international monitory fund 3rd edition:
Colombia University.
Journal reference
Negarit Gazeta of the Federal Democratic Republic of Ethiopia (2002) Value added tax
proclamation no. 285/2002: finfinne,
Tefera, A.H. (2004) Assessment on the VAT implementation in Ethiopia. UN conference
centre,A.A
Wollela Abehodie Yesegat, (2008). Value added tax administration in Ethiopia Finfinne
University.
Website reference
Ethiopian revenue and custom authority:www.mor.gov.et/ercaweb /index /html.
http://www.dictionary.cambrige.org/
http://www.iiste.org/books /
http://www.iiste.org/journals/
http://www.merriam-webster.com/
http://www.oed.com/

APPENDIX
RIFT VALLEY UNIVERSITY BURAYU CAMPUS
Faculty of Business and Social Sciences
Department Of Accounting and Finance
Dear Respondents:
The purpose of the questionnaire is to collect information from the credit customer of the
commercial bank of Ethiopia Burayu Branch for research purpose so believe that there is nothing
behind the study and all your response would be confidential .Hence you are kindly requested to
fill the questionnaires given below. We are grateful and forward our thanks for what you are going
to do.
General Instruction
Please read the question meticulously and forward your answer as there are options for each
question. Please feel free to fill the questionnaire and thanking you in advance for your

25
cooperation and put tick (‘X’) mark and write your own opinion on the space provided to provide
your answer as appropriately.

PART 1: Personal information

1. Age :18-20 21-50 above 51

2. Sex: Male Female

3. Educational level : Master Degree Diploma


certificate if any ---------------------------

4. Marital status: single married divorce

5. Experience:2-5 6-10 11-15 16-20


above 20

PART II: Questionnaires related with challenges and opportunities of VAT

6. Do you think that you are giving enough understanding for the society to pay VAT?

Yes No if any ___________________

7. Do you think that the business process in the company is favorable for VAT payer?

Yes No if any ___________________

8. Are value added tax registered report their invoice properly and timely basis?

Yes No If any _______________

9. Is the perception of the society is enough about VAT?

Yes No if any________________

10. Do you think that there is enough human resource to serve the VAT registered?

Yes No if any ________________

11. Is there modern equipment to treat the customer in mechanized way?


Yes No if any ____________________

12. Is there enough station to serve the VAT payer in a mechanized way?

Yes No if any ____________________

13. Is there any way of controlling the VAT register at the time of fraud on VAT payment?

Yes No if any ___________________

27

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