Consumption tax on electronic commerce (‘e-commerce’) is a matter of concern for both the OECD and the Australian taxation authorities.

The OECD established a legal framework for consumption taxation of electronic supplies in a cross-border trade environment. Based on these principles, the EU adopted VAT rules on electronic supplies. Australia has been reluctant thus far.This article examines whether the amended EU-VAT Directive might serve as a model for Australia’s GST regime. The VAT and GST legislation of both the European Union and Australia is analysed and compared, with particular focus on cross-border e-commerce supplies and enforcement issues. The political and administrative aspects of EU-VAT Directives are also considered. The article concludes that the provisions of the EU-Directive concerning e-commerce are transferable to the Australian GST regime.