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Abstract

While the VAT has risen to dominance within a short span of time, issues relating to VAT refunds like frauds and delays in refunds have haunted the VAT systems around the world. This paper seeks to compare the experiences of three jurisdictions with the VAT the European Union, Brazil and China and seeks to plot the points of convergence and divergence in the international experience. Through the paper, the author intends to demonstrate four points: (1) the issues that arise in the area are substantially similar across jurisdictions; (2) these issues are largely administrative/procedural in nature requiring policy rather than simply legal intervention; (3) since the VAT systems differ significantly, the manifestation of these problems differ across jurisdictions; and (4) as a consequence of the unique features of these VAT systems, the solutions to the issues not only may but must differ from one jurisdiction to another.

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