VAT obligations on imported electronic services where foreign supplier fails to register for VAT

The submission contains SAICA’s request for clarity on the liability of a recipient of imported electronic services to account for VAT on these imported services where the foreign supplier is liable but fails to register and account for VAT in terms of the Electronic Services Regulations in South Africa (“SA”), read in conjunction with the South African Value-Added Tax Act No. 89 of 1991 (“VAT Act”).