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1

Cnossen, Sijbren. "German and Austrian VAT Proposals to Combat Carousel Fraud." EC Tax Review 18, Issue 4 (2009): 192–97. http://dx.doi.org/10.54648/ecta2009025.

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There is much ado about carousel fraud, also called missing trader intra-community (MITC) fraud, in the European Union (EU). This article briefly describes carousel fraud and the proposals that have been made to combat this type of fraud. It focuses in particular on the German and Austrian solution, which defines carousel fraud away by proposing a system of comprehensive reverse charging combined with universal cross-checking. The article concludes that this solution throws the baby out with the bathwater.
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2

Wolf, Redmar. "VAT Carousel Fraud: A European Problem from a Dutch Perspective." Intertax 39, Issue 1 (2011): 26–37. http://dx.doi.org/10.54648/taxi2011004.

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The current European Union (EU) value added tax (VAT) system is a breeding ground for carousel fraud. This fraud results in tax losses of several billion euros each year. It also distorts fair competition and may lead to unexpected VAT liabilities. Carousel fraud is triggered by a flaw in the VAT regime, where the right to deduct VAT is not linked to the prior receipt of this VAT by the tax authorities. A customer can deduct VAT, even if its supplier does not pay the VAT to the tax authorities. Tax authorities may thus end up paying back VAT they never received. The author describes the develo
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3

Burianova, Olga. "Value Added Tax Fraud in the Judgments of the Court: Why We Should Know Our Business Partners?" Advances in Image and Video Processing 12, no. 3 (2024): 353–60. http://dx.doi.org/10.14738/aivp.123.17062.

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This article analyses the judgment of the Supreme Administrative Court, which concerns carousel fraud in Value Added Tax. In particular, it examines the issue of supplier-customer relationships in defined types of markets where carousel fraud can be traced. The aim of the paper is to analyse the judgment of the Supreme Administrative Court and to point out the threat of wrongly selecting a supplier and the threat to added value in economic activity. The resulting question is: Why should we know our business partners? The results of this paper can be a lesson for entrepreneurs, but also for oth
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4

Hangáčová, Natália, and Tomáš Strémy. "Value Added Tax and Carousel Fraud Schemes in the European Union and the Slovak Republic." European Journal of Crime, Criminal Law and Criminal Justice 26, no. 2 (2018): 132–59. http://dx.doi.org/10.1163/15718174-02602005.

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The aim of this contribution is to elaborate on the institute of VAT frauds, with emphasis on Carousel frauds. This document provides compact information concerning VAT fraud schemes within the European Union, problems within the EU VAT system, which was put into force in 1993 and strategises how to tackle VAT frauds as well as de lege ferenda proposals, especially in a view of the European Commission’s proposed solution on the EU’s common system of VAT. This article focuses on details of functioning of the EU VAT system, it explains relevant sections of the Slovak Penal Code Act pointing out
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5

Mielniczuk-Stelmach, Marta. "CAROUSEL FRAUD IN VAT IN FISCAL INSPECTORATE ACTIVITIES." Prace Naukowe Uniwersytetu Ekonomicznego we Wrocławiu, no. 488 (2017): 126–35. http://dx.doi.org/10.15611/pn.2017.488.11.

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6

MACIEJCZYK, Robert. "THE CAROUSEL FRAUD AND THE STATE FINANCIAL SECURITY." National Security Studies 15, no. 1 (2018): 373–84. http://dx.doi.org/10.37055/sbn/132168.

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Opracowanie dotyczy analizy jednego z głównych przestępstw gospodarczych, jakim jest wyłudzenie podatku, oraz jego wpływu na poziom bezpieczeństwa ekonomicznego państwa. Przedstawiono problematykę przestępstwa wyłudzenia podatku oraz mechanizmów procesu wykrywczego i przeciwdziałania temu przestępczemu procederowi.
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7

Pauch, Dariusz. "Carousel Fraud as a Form of Fraud in the Value Added Tax." Annales Universitatis Mariae Curie-Skłodowska, sectio H, Oeconomia 50, no. 1 (2016): 621. http://dx.doi.org/10.17951/h.2016.50.1.621.

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8

ODAINIC, Mariana. "Frauda TVA: unele mecanisme de combatere a acesteia în legislația specializată a U.E." Studii Juridice Universitare, no. 2 2021 (February 28, 2022): 71–83. https://doi.org/10.5281/zenodo.6400711.

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<strong>VAT Fraud and Some Control Mechanisms Reflected in the Specialized Legislation of the E.U.</strong> VAT is the indirect tax that has the largest share in the accumulation of tax revenues from indirect taxes. Due to the impact it has on the EU budget, the losses generated by VAT fraud are huge. In order to reduce it, the European Union regulates various preventive measures, including reverse charge with VAT. In the paper below we present some mechanisms found in the specialized legal framework, focusing on Council Directive 2006/112 / EC of 28 November 2006 on the common system of value
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9

Kerremans, Koen, Isabelle Desmeytere, Rita Temmerman, and Patrick Wille. "Application-oriented terminography in financial forensics." Terminology 11, no. 1 (2005): 83–106. http://dx.doi.org/10.1075/term.11.1.05ker.

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This paper covers ongoing terminography work in the FF POIROT project, a European research project in which formal and shareable knowledge repositories (i.e. ontologies) and ontology-based applications are developed for the prevention of value added tax carousel fraud in the EU and the detection of securities fraud. We will emphasise that the knowledge requirements regarding users and applications determine what textual information should be structured at macro- and micro-levels of the FF POIROT multilingual terminology base. Furthermore, we will present our ideas concerning a multidisciplinar
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10

Nowak, Tomasz. "Rozwiązania prawne wprowadzone w latach 2015–2019 w Polsce w celu uszczelnienia systemu podatku od towarów i usług – analiza i ocena wpływu na dochody budżetowe, pewność obrotu gospodarczego i koszty prowadzenia działalności gospodarczej." Studia BAS 4, no. 64 (2020): 51–67. http://dx.doi.org/10.31268/studiabas.2020.30.

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This paper investigates the effects of legal solutions introduced to the VAT system in Poland in 2015–2019 to prevent VAT fraud, primarily carousel fraud, which caused the so-called tax gap. The article begins with chron­ological presentation of these solutions. In the second part the author formulates the criteria of certainty of business transactions in relation to VAT and on this basis he analyses the presented solutions. Next, he considers the costs incurred by the VAT payer to meet the obligations or requirements established by the introduced regulations. In the final section the effectiv
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11

Gajewski, Dominik J., and Kamil Jonski. "Article: ‘VAT Gap’ Estimation: Distinguishing Between Informality and Fraud." EC Tax Review 31, Issue 3 (2022): 124–30. http://dx.doi.org/10.54648/ecta2022012.

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The value added tax (VAT) remains a primary source of budget revenues across Europe. Consequently, compliance with it became critical for the fiscal security of Member States. Consequently, the issue of VAT compliance received EU level attention, and quantitative indicators – known as ‘VAT gaps’ – were produced for particular countries and the entire EU. Unfortunately, the most common top-down approach to the ‘VAT gap’ calculation delivers only the aggregate estimate of noncompliance. However, designing effective policy interventions requires a more detailed diagnosis as countering organized c
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12

Leszek Wilk. "Criminal aspects of tax delinquency." Archives of Criminology, no. XXXI (January 1, 2009): 209–21. http://dx.doi.org/10.7420/ak2009i.

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There is a common opinion that fiscal offence has no criminal character but is merely an administrative offence and consists only of petty deeds of little social noxiousness. This opinion is not accurate with regard to basic types of tax crimes which very often are varieties of common frauds or forgery that may seriously endanger financial transactions of a country or local government. They are characterised by the fact that the tax procedures and legal structures are faked or falsely initiated and employed to commit or de facto to camouflage offences of criminal character. One example could b
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13

Vaškovič, Miroslav, Hana Zídková, and Markéta Arltová. "The volume of MTIC fraud between Poland and Czechia in electronic devices trade: general method of carousel fraud estimation." International Journal of Economic Policy in Emerging Economies 1, no. 1 (2021): 1. http://dx.doi.org/10.1504/ijepee.2021.10035132.

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Vaškovič, Miroslav, Hana Zídková, and Markéta Arltová. "The volume of MTIC fraud between Poland and Czechia in electronic devices trade: general method of carousel fraud estimation." International Journal of Economic Policy in Emerging Economies 20, no. 2 (2024): 126–45. http://dx.doi.org/10.1504/ijepee.2024.141565.

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15

Greggi, Marco. "Neutrality and Proportionality in VAT: Making Sense of an (Apparent) Conflict." Intertax 48, Issue 1 (2020): 122–31. http://dx.doi.org/10.54648/taxi2020009.

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Neutrality and proportionality are two features of the European VAT that often come into play when judiciary is requested to rule on alleged frauds to the tax. According to the well settled case law of the European Court of Justice (ECJ) the right to deduct VAT can’t be granted when such a fraudulent operation occurs. In the EN.SA. case, to the opposite, the Court rules that neutrality is to be preserved even when the operation invoiced did not actually take place, if very specific circumstances are met: namely, that no loss for the national budget occurred, that the company invoiced was not a
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16

Abdyldaeva, Nargiza, and Kanybek Sarymsakov. "THE PROBLEM WITH THE ELECTORAL SYSTEM OF THE KYRGYZ REPUBLIC – THE ELECTORAL CULTURE OF THE VOTER." Alatoo Academic Studies 22, no. 2 (2022): 193–99. http://dx.doi.org/10.17015/aas.2022.222.24.

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Since 2015, the Kyrgyz Republic has introduced a new model into the electoral system, thereby eliminating many types of fraud. For example, falsification of the election results took place, bypassing the voters themselves, by the following methods: carousel – when the same person voted many times; dead souls – there were citizens on the voter list who were miraculously healed during the electoral period; dumping of ballots – “skillful hands” members of the precinct commission. After the introduction of the new model, all of the above-overpowered types of falsification have exhausted themselves
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17

Aujean, Michel. "Towards a Modern EU VAT System: Associating VIVAT and Electronic Invoicing." EC Tax Review 20, Issue 5 (2011): 211–16. http://dx.doi.org/10.54648/ecta2011025.

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In spite of all traditional anti-fraud measures adopted these last few years, the carousel fraud is still there. Moreover, the risk is becoming high for honest traders of being involved in such fraudulent transactions and the consequences can be very damaging for them. Time has come to reconsider solutions that would eliminate what makes such fraud so attractive: breaking the VAT chain by zero-rating intra-EU supplies of goods (i.e., the possibility to buy goods without immediate payment of VAT). Viable Integrated VAT (VIVAT) is such a solution. Under that proposal, a common rate of VAT would
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18

Semerád, Pavel. "Carousel fraud in fuel and its solution from the viewpoint of the Czech VAT Act." Annual Center Review, no. 9 (2016): 6–11. http://dx.doi.org/10.15290/acr.2016.09.02.

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19

Efstratios, Pourzitakis. "Halting the Horses: EU Policy on the VAT Carousel Fraud in the EU Emissions Trading System." EC Tax Review 21, Issue 1 (2012): 39–51. http://dx.doi.org/10.54648/ecta2012005.

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The European Union (EU) Emission Trading System (ETS) has been a major tool of the EU climate policy. Despite its significance, the EU ETS faces serious challenges regarding its function. One of the major issues that encumber its contribution in EU climate policy is value added tax (VAT) carousel fraud within it. This paper examined the ways this type of swindle is conducted and its economic impact. It analyses the parameters that facilitate it and evaluates the responses of the EU and its Member States and mainly the introduction of the reverse charge mechanism. It finally highlights the need
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20

Lošonczi, Peter, Josef Reitšpís, and Martin Mašľan. "Legal and Policing Model to Counter Organised Crime and Terrorism in Slovakia." Security Dimensions 29, no. 29 (2019): 127–39. http://dx.doi.org/10.5604/01.3001.0013.4400.

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Organized crime and terrorist networks belong to the most important threats in Europe, including Slovakia. The number of assets confiscated from organized crime is still increasing, which indicates its rise, especially in the areas of carousel tax fraud, unlawful financial operations, VAT collection, and the distribution of drugs. These activities are often accompanied with corruption. Europe, including Slovakia, is now facing the growing migration wave that increases the risk of foreign fighters entering its territory, who could be recruited for terrorists attacks. The efficiency of the fight
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21

Slemrod, Joel, and Tejaswi Velayudhan. "The VAT at 100: A Retrospective Survey and Agenda for Future Research." Public Finance Review 50, no. 1 (2022): 4–32. http://dx.doi.org/10.1177/10911421221094595.

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We take stock of what is known about the consequences of actual value-added tax (VAT) systems, nearly 100 years since its conception. We benchmark it to the tax it most often replaced—the retail sales tax (RST). We do this not because we advocate a return to the RST, but because it allows us to evaluate the performance of two tax instruments in actual practice instead of comparing them to their idealized versions, which are never achieved. Doing so highlights different areas of focus than traditional comparisons to the “good” VAT. Like the RST, the VAT is weak at the final stage and technologi
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22

Semerád, Pavel. "How to Avoid the Usual Price Rule on the Fuel Market in the Czech Republic." Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis 64, no. 1 (2016): 351–55. http://dx.doi.org/10.11118/actaun201664010351.

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The paper deals with value added tax evasions on the fuel market in the Czech Republic. This commodity is used in carousel fraud. In the chains of taxpayers there are missing traders who fail to meet their tax obligations. Their business strategy is based on quick sales at unusually low prices which do not allow honest parties to compete. Tax administrators should focus on unusual prices which constitute a higher probability of tax evasions. This paper aims to verify whether or not there are ways to evade the measure, focusing specifically on applying methods which could help achieve lower sal
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23

Sokanović, Lucija, and Luka Pribisalić. "Kružne prijevare." Hrvatski ljetopis za kaznene znanosti i praksu 30, no. 2 (2023): 339–70. http://dx.doi.org/10.54070/hljk.30.2.5.

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Kružne prijevare ili carousel fraud posebna su vrsta prijevare unutar Europske unije uz pomoć trgovca koji nestaje sa sljedećim temeljnim elementima: transakcije poduzeća u najmanje dvije države članice, veliki broj kupoprodajnih transakcija više poduzeća u kratkom razdoblju te najmanje jedan nestajući trgovac. Riječ je o posebnoj financijskoj prijevari kojom se oštećuje državni proračun zlouporabom sustava poreza na dodanu vrijednost te posljedično i proračun Europske unije.Ciljevi su rada analizirati dinamiku nastanka i razvitka kružnih prijevara proučavanjem razvoja sustava poreza na dodanu
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24

Sikharulidze, A. "“Irregular” Democracy: The Parliamentary Elections in Georgia." Russia and New States of Eurasia, no. 4 (2024): 166–81. https://doi.org/10.20542/2073-4786-2024-4-166-181.

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The parliamentary elections in Georgia took place amidst polarization and confrontation, not only internal but also external. The Georgian opposition fully relied on Western support, which shifted in their favor after the start of the conflict in Ukraine. Meanwhile, the Georgian Dream party focused on domestic voters, actively engaging with citizens in various regions of the country. The ruling elite managed to secure another victory, which shocked the opposition and representatives of the Western establishment. Protests are ongoing with demands for new parliamentary elections based on “fairne
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Synyutka, Nataliya H. "The Fiscal Efficiency of VAT Electronic Invoicing System in the Domestic Market of Ukraine." Business Inform 11, no. 550 (2023): 271–79. http://dx.doi.org/10.32983/2222-4459-2023-11-271-279.

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The objectives of the introduction, the content and impact of the reform of electronic administration of VAT through the indicators of fiscal efficiency of value added tax in Ukraine are generalized. The assessment of the fiscal efficiency of the tax was carried out using a set of annual indicators of the effective tax rate in relation to GDP and the end domestic consumption of goods and services. It is proved that digital transformations in taxation primarily stimulate the transparency of taxation procedures. The indicators of actual VAT revenues for the period 1997–2022 are summarized. The m
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Teszner, Krzysztof. "Country Note: Customs And Fiscal Control In Poland As A Radical Measure To Eliminate Tax Evasion." Intertax 48, Issue 10 (2020): 922–28. http://dx.doi.org/10.54648/taxi2020090.

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Many European countries with stable market economies have recently taken measures to seal their own tax systems. A noticeable phenomenon are the modifications in the organization and functioning of tax administrations and in the existing procedures for the control of taxpayers with respect to the tax law. Customs and fiscal control, which was recently introduced in Poland, is an example of a new control procedure aimed at eliminating tax evasion and combating tax fraud, especially carousel transactions in value added tax. The introduction of this control was preceded by the establishment of a
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27

Sato, Alexej. "Carousel Frauds in the Czech Republic." Journal of Finance and Accounting 2, no. 6 (2014): 1. http://dx.doi.org/10.11648/j.jfa.s.2014020602.11.

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28

Nieuwenhuizen, Wilbert A. P. "The solution for combating VAT carousel frauds." EC Tax Review 16, Issue 5 (2007): 213–15. http://dx.doi.org/10.54648/ecta2007036.

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29

Sheranova, Arzuu. "Cheating the Machine: E-voting Practices in Kyrgyzstan’s Local Elections." European Review 28, no. 5 (2020): 793–809. http://dx.doi.org/10.1017/s1062798720000241.

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This paper analyses the e-voting experience of the local elections undertaken by Osh city Council in 2016. The process was introduced to ensure fair and democratic elections in Kyrgyzstan after continuous and repeated violent political uprising. The e-system, based on biometrics registration, biometric identification of voters and automated vote counting, was designed to help to avoid the most common election frauds: vote buying, carousel voting and group/family voting. The case study, mainly based on interviews, illustrates the adaptation and modernization of strategies to resist and cheat wi
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30

Krzikallová, Kateřina, and Filip Tošenovský. "Is the Value Added Tax System Sustainable? The Case of the Czech and Slovak Republics." Sustainability 12, no. 12 (2020): 4925. http://dx.doi.org/10.3390/su12124925.

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The value added tax is an important part of revenues of the European Union and its Member States. The aim of the paper is to statistically analyse the extent of positive impact of selected legislative measures introduced in the fight against tax evasion and discuss subsequently the sustainability of the current value added tax system in the European context. The analysis was conducted for the Czech and Slovak Republics, two traditionally strong trading partners, and for an important commodity, copper. In the analysis, regression methods applied to official time series data on copper export fro
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31

Wolf, R. A. "The Sad History of Carbon Carousels." International VAT Monitor 21, no. 6 (2010). http://dx.doi.org/10.59403/bhvdyc.

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Carousel fraud is no longer confined to transactions involving goods. The recent incidence of carousel fraud in the market for CO2 emission rights demonstrates that carousels can also involve intangibles. In this article, the author discusses the trade in CO2 emission allowances, the carousel fraud in the carbon market and how the fraud may affect legitimate businesses operating in that market, the measures that were taken to combat the fraud, and the ideas for a more comprehensive solution to stop this type of fraud.
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32

Olexová, Cecília, Milan Husťák, and František Sudzina. "Carousel fraud in terms of price manipulation." Journal of Financial Crime ahead-of-print, ahead-of-print (2021). http://dx.doi.org/10.1108/jfc-07-2021-0169.

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Purpose The purpose of this paper is to analyse the effects of carousel fraud on the average price of goods, as one of the negative economic aspects of carousel fraud. Design/methodology/approach This paper is primarily based on the description of selected legal cases and the modus operandi of carousel fraud, the analysis of legal texts (legislation and judgments of courts) and the discussion, from the point of view of price manipulation. Findings The results of the analysis specify the negative impact of carousel fraud in the form of the distortion of reported average prices and suggest that
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33

Hoffmann, Eiko. "Umsatzsteuerkarussell – Modelle zur Bekämpfung des Missbrauchs." April 17, 2020. https://doi.org/10.5281/zenodo.3755571.

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This publication shows the historical development of VAT fraud, the functioning of the VAT carousel as a fraud model, and the model for combating VAT fraud.&nbsp; The VAT carousel is a fraud model aimed at tax evasion and is one of the most damaging manifestations of tax crime in recent years.&nbsp;A VAT carousel is an association of several companies that take advantage of the possibility of deducting input tax on cross-border deliveries to reduce the price of the goods delivered onward while at the same time not paying the VAT amounts owed. The possible models for combating fraud are the rev
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34

Lebiedowicz, Andrzej. "Polski model prowadzenia śledztw w sprawach oszustw podatkowych popełnianych metodą karuzelową." Kwartalnik Krajowej Szkoły Sądownictwa i Prokuratury, September 30, 2023, 19–49. http://dx.doi.org/10.53024/2.3.51.2023.

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This article is devoted to an analysis of the Polish model of conducting an investigation in cases of tax fraud committed with the carousel method, clearly indicating the superiority of the offensive (dynamic) type over the static (conservative) type. It concerns the economic evolution of an organized crime and discusses the carousel mechanism, raising the issue of carousel crimes and their legal qualification. The article presents the main features of a dynamic and static model through the prism of specific goals facing investigators in this type of case. Finally, it presents selected methodo
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35

Berrittella, Maria, and Filippo Alessandro Cimino. "An Assessment of Carousel Value-Added Tax Fraud in The European Carbon Market." Review of Law & Economics 13, no. 2 (2017). http://dx.doi.org/10.1515/rle-2014-0023.

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AbstractThe literature on the European Union Emission Trading System (EU ETS) is by now very rich. Much is known about the efficiency, the effectiveness, and the environmental and distributional impacts of the EU ETS. Less, however, is known about the carousel value-added-tax (VAT) fraud phenomena in the European carbon market. This article evaluates the welfare effects of carousel VAT fraud in the EU ETS using a computable general equilibrium (CGE) analysis. According to our findings, if VAT fraud occurs in the EU ETS, the effects on welfare for the EU Member States are negative, with welfare
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36

Brederode, R. F. van, and S. Pfeiffer. "Combating Carousel Fraud: The General Reverse Charge VAT." International VAT Monitor 26, no. 3 (2015). http://dx.doi.org/10.59403/3q2gzy2.

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Fraud schemes, generally, exploit the application of the zero rate to cross-border trade. Most proposals try to tackle fraud by either taxing the transactions or securing payment. In this article, the authors take an opposite approach and describe a general reverse charge as a means to remove the incentive for VAT fraud.
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37

Aujean, M., C. Valenduc, and M. Wolf. "Reform of the EU VAT System for Intra-Community Transactions." International VAT Monitor 24, no. 1 (2013). http://dx.doi.org/10.59403/g9c0r0.

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From a macroeconomic perspective, increasing the rate of VAT seems to be one of the most widely used policy instruments for budget consolidation. Unfortunately, the EU VAT system, and notably the system of taxing intra-Community transactions, is highly vulnerable to missing-trader fraud (“carousel fraud”) and higher VAT rates make the VAT system even more attractive for fraudsters. In this article, the authors argue that associating VIVAT with an adequate electronic monitoring of transactions offers an effective solution.
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"Carousel Value Added Tax Fraud: Why It Is Difficult to Face." Advances in Image and Video Processing 12, no. 2 (2024). http://dx.doi.org/10.14738/aivp.122.16523.

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39

Berrittella, Maria, and Filippo Alessandro Cimino. "The Carousel Value-Added Tax Fraud in the European Emission Trading System." SSRN Electronic Journal, 2012. http://dx.doi.org/10.2139/ssrn.2175482.

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40

Lamensch, M. "Should the Italmoda Jurisprudence Apply to Carousel Fraud Involving Services? The ECJ's Pending Climate Corporation Emissions Trading Case." International VAT Monitor 33, no. 3 (2022). http://dx.doi.org/10.59403/3n08k6n.

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In the well-known Italmoda case,the ECJ decided that the exemption (zero rate) of the intra-Community supply should be denied when the supplier “knew or should have known” that, by his supply, he was participating in a transaction connected with fraudulent evasion of VAT. In the pending Climate Corporation Emissions Trading case, the question is raised whether a similar approach should apply to intra-Community supplies of services. In this article, the author suggests that this pending case highlights the urgent need for a comprehensive solution to the issue of carousel fraud in the European U
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41

Ainsworth, Richard Thompson. "American VAT – The Carousel Fraud Threat: Will the EU Show the US the 'Way Forward'." SSRN Electronic Journal, 2013. http://dx.doi.org/10.2139/ssrn.2309426.

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42

Toma, Giangaspare Donato. "VAT Carousel Fraud in the EU : The need for Reform in Italy and on a Supranational Level." eucrim - The European Criminal Law Associations' Forum, 2014. http://dx.doi.org/10.30709/eucrim-2014-012.

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43

Ainsworth, Richard Thompson. "MTIC (Carousel) Fraud: Twelve Ways Forward; Two Ways 'Preferred' - Has the Technology-Based Administrative Solution Been Rejected?" SSRN Electronic Journal, 2008. http://dx.doi.org/10.2139/ssrn.1103883.

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44

Podlipnik, Jernej. "Missing Trader Intra-Community and Carousel VAT Frauds – ECJ and ECtHR Case Law." Croatian Yearbook of European Law and Policy 8, no. 8 (2012). http://dx.doi.org/10.3935/cyelp.08.2012.135.

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