Tax Implications of Industry 4.0

Changes in the way of doing business such as supply chain, introduction of new products or services, additional capital expenditure, or product customization can all have an impact on tax treatment. By understanding the shift, status and impact created by Industry 4.0, businesses can create a tax strategy and framework to successfully adapt to the new tax environment. Based on this, we illustrate the potential tax implications of Industry 4.0 by examining the role of three key shifts in boosting growth and strengthening operations:

Factories: Creating digital connections between operations and information technology

  • Direct Taxes: Availability of Tax Credits; Pricing of Related Party Purchases and Application of Transfer Pricing Models
  • Indirect taxes: Deduction and management of input VAT (including cash flow) generated from purchases; VAT treatment of costs advanced within the group; complexity of the classification of professional and technical equipment tariff rates
  • Employment Tax: Adjustment of compensation and incentive programs, and related tax issues

Support: Informatization and extended after-sales service

  • Direct tax: Possibility of forming a permanent establishment; changes in corporate income tax; creation of taxable income from holding shares
  • Indirect taxes: Additional indirect tax obligations arising in new territories; Consideration of whether to supply goods or services (both have different VAT rules); Determination of reporting requirements; Impact on valuation of goods from a customs perspective; impact of export controls
  • Employment tax: Short- and long-term employee turnover creates new compliance obligations

Customers: Connecting and Integrating in New Ways

  • Direct tax: Identify where the supply occurs to determine the effective tax rate on profits; Consider where the operating management center is located (e.g. in low-tax locations)
  • Indirect Taxes: Different VAT treatment for provision of new services; Additional VAT registration requirements for electronic services; More challenging to determine classification, valuation and origin of goods for tax purposes due to increased customization
  • Employment Tax: Emphasis on Additional Supplementary Services

From a tax perspective, there are several key action points that some businesses can consider: if, how and when to implement Industry 4.0 technologies.

  • Consider upfront tax status
  • Ensures effective communication between operational departments within the enterprise
  • Whether the business wants to play an active role in setting tax policy
  • Be aware of other factors that affect taxation