Viable for VAT? Verifying the Ins and Outs of Domestic and Foreign Tax Compliance with Blue dot

Employees are back to traveling for business, and with it, the requirement to track both domestic and foreign expenses for tax compliance initiatives abroad. “There were a lot of complex processes,” Jeanne Dion, Vice President of the Value team, recalls in a previous life when she worked in tax. “Whether it was VAT or any other type of tax… it required a certain amount of… manual effort from our employees.” Still, Blue dot finds 23% of expense reports have tax information that’s wrong. “There were about 100 changes that had happened across a number of countries, which in itself is a big number,” shares Dr. Mark Stirling, Sr. Vice President of Global Channels at Blue dot. “If you think about all the people… in that process, every one of them would have to be trained on this and take some action.” Join us for this episode as Dr. Mark Stirling discusses tax compliance with SAP Concur Conversations.

This four-episode podcast series celebrates Blue dot as one of the SAP Concur Partner Award recipients. Listen to each of these featured award winners on our podcast channel, SAP Concur Conversations, for best practices and more. You can also listen to this episode on: Apple | Amazon | Spotify | ListenNotes | Acast | Audible or Google your favorite place to find podcasts.

Jean Dion:

Hi, I'm Jean Dion here today on the SAP Concur Conversations Podcast. I'm the Vice President of the Value team here at SAP Concur. Our role is to work with customers to solve business problems and to work on their goals and objectives in support of their corporate roles.

Today I have with me one of our Partner Innovation Award winners, Dr. Mark Stirling from Blue dot, and we're going to talk about tax. Tax can be really confusing, but Mark has a great way of explaining and making it all simple. So Mark, I'd like to go ahead and let you go ahead and introduce yourself.

Dr. Mark Stirling:

Sure. Thanks Jean. My name's Mark Stirling, as Jean said, from Blue dot. I'm a senior vice president of global channels for the organization, responsible for working with our key partners to bring our joint technologies to market, supporting them in not only the delivery of these services to their customers, but helping to ensure the customers are maximizing the value from those services once they have decided to use them.

Jean Dion:

Great, thanks. So I want to dive right into this, because tax can be a complicated thing. I remember in a former life, I had to work along that tax and thought mostly about it as a compliance issue, and I knew there were a lot of complex processes that were required in order to reclaim tax, whether it was VAT or any other type of tax, and it required a certain amount of, well, actually a significant amount of manual effort from our employees.

Whether they were a traveler or somebody in the back office doing the reconciliation and auditing of receipts or et cetera, it was a lot of work and it seemed to be somewhat confusing for everyone. So, I was wondering if you could tell me a little bit about what Blue dot does to relieve some of that pain? Kind of walk me through that process for tax reclaim. I was wondering if we could start with the difference between domestic and international VAT collections?

Dr. Mark Stirling:

Of course, let me try to summarize. As you say, there are two main domains within the recovery of VAT around the world. Countries might call it a different thing, but I'll refer to it as VAT for the purpose of this session. Domestic, let's start with definitions of what domestic means. Domestic relates to the country of the employee that's concurring the spend. So as you can probably all tell from my accent, I based here in the UK, so for me, the UK is my domestic. My colleague who's based in Paris will have France as their domestic.

The way it works within the realms of VAT, especially the VAT that's concurred on employee-based spend is that all the spend that I incur in my own country that we can demonstrate and prove is for business purpose that is eligible and qualifies with the rules can be reclaimed by my employer as part of their domestic VAT processes. It's actually a deduction that they put together.

So, you need to understand what did I do? Where was I? Traveling in the UK, business traveling the UK, staying in a hotel, using my car and so on. Then we need a process to track that that spend was incurred, that it's legitimate, that I've got the right supporting evidence, and then to aggregate it all together and put it in the financials as a deduction on our next return.

Critical to understand there's no money transfer's hands here. The government doesn't reimburse this money typically, it's a deduction. Actually, you could describe it simply as a trust system, but the authorities can come in and audit. So, they will ask to come in and they'll check the controls that you have in place on those processes. How do I as a traveler understand what I'm doing? How does the employer understand that it's legitimate, that we have the right evidence? If the controls are found to be lacking, the authorities can impose sanctions leading through to fines and penalties for non-compliance. That's the process that's associated with domestic.

Now I talk about fines and penalties for non-compliance, of course these days, in fact, the bigger concern is more likely to be getting on the authorities’ blacklists, and often organizations will find themselves in the news for VAT challenges. So yeah, there's a lot of reasons why you want to make sure you get this process right.

The other part of this process is foreign VAT. You call international, I'll say foreign. So foreign VAT, again, it's foreign to me as a person. So for me traveling to Paris, all the spending that I've now done in France would be my foreign VAT. My French colleague who's traveling with me in France however, for him, that would be domestic. So there are various treaties in place around the world on which countries will reimburse VAT to other countries, but in this basis France will reimburse certain aspects of their VAT to a UK-based organization.

So similarly, I need to track and expense every part of my journey, my employer that needs to go through the process of qualifying, auditing, understanding exactly what I did, demonstrating, beyond reasonable doubt, that this was incurred in the course of doing business and the spend is eligible. Then they go through a submission process where, through various mechanisms depending on some of the nuances around the world, you submit a request to the foreign authorities to reimburse the VAT you believe you're entitled to from that country.

It goes into their authorities, they review your request, which are typically line itemized, and should they agree with your requests, they will then remit the funds back to you, so physical money transfer's hands. So unlike domestic where the penalties for doing it wrong are that they'll come in and audit you and you can get in trouble with the authorities, for foreign, there's a lot of complexity in the submission processes and the penalties for getting it wrong are that you will not get the money back, so you lose money in that instance.

Jean Dion:

So when I hear that, when I hear that description, two things pop into my head. It's the quality of the data, and it's the risk that a company runs when they're going through a reclaim process of really identifying. Because at the end, as we all know, there is the possibility of audit, and so every time that there is a misstep within the process, you risk something of consequence for your company.

So, I know there are two different pieces of reclaiming the VAT. I know it's eligibility and disqualification, and if you wouldn't mind telling me the difference between those two and how we can use that to let's first tackle that risk part of it. What's the difference between eligibility and disqualification and how does it tie to your tax reclaim process?

Dr. Mark Stirling:

Oh, of course. I'll pick up on that word risk, because of course one of the reasons we're here is to reduce and remove that risk, and that's what we're going to be talking about in this process. So the two concepts, eligibility and disqualification. Eligibility refers to the VAT that is in your, in this case, your expenses, that you could reclaim should all things be perfect in the way that the data is there.

There are examples around the world, they're always changing, but there are examples around the world where spend may not be eligible. There may be a country, for example, that just simply doesn't reimburse VAT to vote from another country, it's referred to as reciprocity, and the treaties that are in place just may not allow that to happen. So, it doesn't matter how much you spend as a business traveler traveling from one country to another if that country won't reimburse it.

There are also some local rules where countries will not allow you to reclaim elements of your spend. There's an example that I often talk about in France, where hotel rooms, that the hotel line itself in France is just not something you're allowed to reclaim. So even if the VAT is there, it's not eligible. There's nothing we can do about that, right? That's the law, that's the way the rules work.

The second concept though, which is something we can control, when I say we, I'm talking about all of us as business travelers, or as people who spend on behalf of our employer, and that is disqualification. Disqualification refers to the VAT that you could get back, but you've not been able to get back, because something's wrong, you've not got the right evidence.

There are examples around the world in you don't have the right address on a receipt, you've got a credit card slip rather than the correct hotel [inaudible 00:09:45], for example. Disqualification is something you want to target. You want to understand why am I not getting the VAT back? What can I do to improve that position? Is it a question of training? Do my employees not have the right knowledge? Have I not got the right processes or visibility and reports into that data to allow me to do that?

Jean Dion:

So that's a great segue, because as I mentioned, I think there's two pieces to that VAT reclamation. It's the risk and controlling that risk, but it also requires a lot of data mining based on rules. I'm just curious, because I know I live in the US, so our tax rules are constantly changing and there's always some sort of flux around interpretation.

So when I think about this overall, are the rules really steady or do they change frequently? I can imagine that it's probably difficult to keep all these rules straight, especially if you're an organization that's working in 10, 15, 20, 40, 70 countries around the world. Is that the case? Is it hard to keep it straight? If you could just kind of give me a simple version of what's happening in the world as it relates to rules.

Dr. Mark Stirling:

I mean, the simple answer is yes. What we're finding and the reason why we do what we do is that organizations are not set up for the purpose of managing their VAT. All organizations are set up for the purpose of doing their line of business, that's what they do. The knowledge, the skills, the processes required to manage the VAT processes in the employee spend are quite complicated. It requires quite a lot of understanding on a number of different parts. You've got to design your expense systems to capture the right data, you've got to have employees that are educated on exactly what should go into that data. You've got to have the right review processes afterwards to ensure that the data that's being, as you say, mined and understood is accurate.

This whole process relies on people. This is what we've learned and this is where we come from as a business in the provision of this service. This historically has been a very manually driven process. Whether you're talking about internal processes or shared service centers, outsourced providers, they rely on people. People have finite memories, people understand their own rules, or you would argue understand some of the rules in their countries. But as you say, no one person can understand the complexity all around the world that goes with this.

So, we start on the premise that we have to remove the person from the process. We have to remove the need for the business traveler or the spender on behalf of the organization understanding exactly what the rules are and whether they have the perfect quality receipt as applied to that in every part of what they do. We have to remove the reliance on people and all these organizations around the world having to research and understand all the changes in the regulations. I'll touch on that in a moment, and we need to remove people from that process of understanding how to review, double-check, insanity check these processes prior to submission.

This is where we come from. We're 100% focused on the automation, and our organization has applied to why we're having this conversation. We're rapidly dominating in the technology space with patented technology, and we're seeing so much demand for this service right now, where the secret source in what we're doing is understanding the expense report, the expense event, adding in all the VAT information that we need totally by technology before taking it forwards and doing the submissions or giving you the data you need to do your deductions and removing humans from the angle.

Now, what we talk about when we talk about the changes and whether this is a steady state thing is we did some research a few months ago actually into the primary countries that our clients are active in, and how many rules had changed around VAT in that time. Bearing in mind, the pandemic had triggered some of this. The number I was given was about 100. There were about 100 changes that had happened across a number of countries, which in itself is a big number. If you think about all the people I just described in that process, every one of them would have to be trained on this and take some action.

If we look at some of these rules, and I'll give, again, a local example to my country, help to eat out, which was a scheme that was introduced to encourage us all after the end of the first lockdown during the pandemic to get back out into the hospitality sector and go to restaurants and help those organizations stay afloat, so the VAT rate was temporarily reduced.

I remember rightly, that reduction was actually extended once, if not twice before that scheme ended, which meant that one change actually became three, if not four changes that needed to be tracked, all of which would've had to have date controls and training that went onto it.

But there's another angle as well, Jean, in this data that I wanted to highlight, which is it's the evolving pattern of the spend itself.

Jean Dion:

Right.

Dr. Mark Stirling:

So the rates and rules are changing, yes, but so is actually the data that we're seeing in the expense systems. Go back a few years, expense systems were largely speaking driven by the same events, business travel. We were booking flights, we were staying in hotels, ground transportation, meals. It was very consistent in what was happening there, and the spend in those systems that wasn't related to a business trip was quite small. In fact, we see it as being less than 5% of the spend that was going through.

Post-pandemic, we've seen quite a significant increase in what you might call the other expense category, the spend that's not associated with the business trip. In fact, up to 25% of the data, according to our analysis, a 20 point increase. I hear you say, yes. This is us at home as travelers, I call it the decentralization of some of the purchasing controls. We as individuals are now making purchasing decisions on behalf of our employer. We're buying laptops and monitors and keyboards and mice from our preferred suppliers using our own cards and putting those through our expense systems. Hopefully everyone recognizes that scenario. It introduces another whole big suite of change, Jean, that I'll highlight.

The first part is those expense types are not consistent anymore. You see a whole variety of spending there that no longer suits a scaled say human process, where if somebody's seen a particular hotel receipt a few times, they think they now know how to interpret that going forwards. Every single line could be different. You've got a much greater level of scrutiny that's needed on that expense as it comes through with the complexity that that will drive. Previously manual processes or work-arounds, or even dare I say it organizations that kind of ignored this [inaudible] because it was so small, it'd become too big a part of the data now and it can't be overlooked.

Jean Dion:

Right. I think this ties back to changes in how we're, to your point, viewing work, but also things that we would never typically think about as what we would call a taxable benefit. Something like phone or internet or hardware to keep your home office going, because now you're working remotely or you have that flexibility. We wouldn't think about reimbursement of that as a benefit necessarily, but in the end, that's really kind of what's happening.

We've also seen on expense reports some other things, like employee recognition or tuition reimbursement. It doesn't mean that they shouldn't be on an expense report, but it means that it requires, to your point Mark, extra scrutiny, and it needs to be thought about in how that's working.

So taxable benefits have always been a thing, we have a lot of data that's coming in. So, can you talk a little bit about where the Blue dot philosophy fits into that? There's the risk that is around it, and then there's also that data mining. I'm assuming that it's the same process that's being used for that particular type of data. Would that be true?

Dr. Mark Stirling:

It is exactly true, yes. I mean, the risk that you're talking about is the risk of the employee, myself, making a purchasing decision, putting that through the system. Unless you've got the appropriate checks and controls in the system, that decision that I made and the way that I chose to code it can flow straight into your financials and can define the financial risk position of the organization. We don't want that.

With employee benefits, fringe benefits, taxable employee benefits, however you would call them, one of the differences here is that it's not optional. Organizations are required to have processes in place to look for and track, and to demonstrate whether you are ruling in or ruling them out to demonstrate that you're looking for what we might call the invisible, the hidden benefits that are flowing through processes.

We all know about the visible benefits, your health insurance that your organization is providing that's been taken care of and the central process and appears through your payroll or your end of year tax declarations, but there's other aspects of it. I'll use an example just to help people understand what might be happening here.

Here in the UK, if you have a personal mobile phone that your employer is reimbursing, then the line rental of that mobile phone is considered to be a taxable benefit that should be submitted as part of your end of year tax declarations to the authorities. You're getting a benefit from your employer, but not necessarily if it's being provided by your employer as a central phone I feel like on their bill and they comply with the rules around that. So, it's super important to scrutinize the data in the same way. From our side, it's a very similar process that we put into controlling this.

Our service breaks down into three core parts. This is true of our VAT service, as well as our benefits service. The first thing that the service is doing is it's looking at that expense event. Which once upon a time was predominantly travel, these days is a much greater spread of the data in that. Understanding what's on the receipt, understanding what the employee thinks they did. Looking for and enhancing the tax data that is associated with that event to truly understand what happened, and removing therefore the burden on the employee or any review processes you've got from developing that understanding.

Then there's the application of the tax rules. Whether those tax rules are the VAT rules or the organization's benefits policy and how that's being developed, to again, understand exactly what you wish to do with that data, how you interpret that data and how it's going to be processed. Benefits are a little bit more subjective and they need to be fine-tuned. So if you're looking at the complexity of it we talked about before, that's where we've removed the human angle I talked about before, we've removed the complexity of understanding all the rules, because we take care of that for you.

Then a third part of it, and it's really important in both VAT as well as benefits is we then have the analytics and the reports and dashboards that will allow you to monitor and improve your position. So, for example, if you see all your employees in the UK are using their personal phones, expensing them and they're all picking up a benefits charge, you may want to consider putting in place a corporate plan and removing that issue from everybody, but also putting in place really clear dashboards and tools for the authorities to look at when they come in to audit you to show that you've got superior controls in place. That's what you get with a service that eliminates the need for people and applies a consistent rule set to the data as it works its way through.

Jean Dion:

That is actually a very good point. It's that overall control, not just control of risk, but control of how you're spending and spending thoughtfully around the different types of things that are showing up on reports and how we're putting it together.

 

There's one piece though that we haven't touched on yet, and it's one of my favorites, it's that new term called bleisure, that blending of business and leisure. We're seeing a lot of expansion of that, especially after the pandemic people are raring to go and get out and travel. If you're going someplace really interesting, the idea that if you have meetings on Monday, maybe you show up on Saturday. How does that tie into taxable benefits? Where does that fit in the overall? Is that something that can be reclaimed from a VAT perspective, or does it fall back into the employee benefits type thing?

Dr. Mark Stirling:

Great question, and it does apply totally to both. So, I talked earlier about the need to really understand the expense report. One thing I didn't touch on is that within our service and overall the years we've been operating, we developed this artificial intelligence brain. Our CTO doesn't like it when I refer to it as a brain, but I think of it as a brain that's evolved just like our own that understands what typical employee-based spend looks like.

What does a business trip look like that I do working from home, what does typical spend at home look like? It's typical patterns of human behavior and it uses it to extract contextual meaning from the expense report. Again, a mechanical process would look at what's on an expense report, because rarely does any technology look at what's on the receipt, it's typically what the employee enters, it's a simple sum of what the employee has entered. But what's our technology looks at is what does it mean?

So, you used that example of traveling over the weekend and adding a couple of days to the business trip and how do we manage that? Think of a scenario where you do a business trip from a Wednesday to Wednesday. I'm based in the UK, let's say I travel to Australia, there's no way I'm going home for the weekend. I need to be there for the week and I need to be there for the weekend, so in that particular scenario it's really easy to say that is valid for business purposes. But the typical leisure that you're talking about, a phrase that doesn't trip off my tongue very easily, I'm not quite used to that yet, would be, yeah, again, my colleague in France.

So I travel to see my colleague in France, and as you say, I tack on a couple of days at the weekend. Those two days in most scenarios are, because it's personal spend, because I stayed there two days over the weekend, I wasn't working, though of course there are some areas where you can demonstrate that you were, those two days are personal spend. As a result of that as its personal spend, not business spend, whether or not your employer chooses to reimburse it, you shouldn't be reclaiming that for VAT purposes, because it's not demonstrable business spend.

Similarly now, if we've identified it as personal spend, and that's what the contextual meaning in our AI is trying to look at, it should now count towards your benefits. So you should track that hotel stay if that's what we're talking about, and it should be fed to your payroll team as part of a taxable benefit, and then there's a company policy on what you do about it. Are you going to gross it up and pay it on behalf of the employee, or is it a charge that gets passed to the employer?

So yeah, you used the example of the weekends, there are plenty of examples actually that qualify. For example, many environments, they look at the percentage of alcohol on a meal receipt, and if a receipt contains more than a certain amount of alcohol, then it can qualify as a personal event or entertainment rather than a business meal. That can have an implication on, again, whether it's considered to be something you can reclaim VAT or whether it should be collected for the purposes of benefits.

Jean Dion:

Okay. When we're talking about those employee benefits, it's if the company has reimbursed the employee for the full hotel stay, right? So, that if an employee has stayed for the weekend and has claimed it as personal and has paid it out on their own and the company hasn't paid it, then it doesn't show up as an employee benefit. Correct?

Dr. Mark Stirling:

Correct, correct. So what our service is looking at, it's the approved spend that is then reimbursed to the employee. That's part of the control here. It's on an expense report, you've reimbursed it as an employer, so we know you've accepted that as a business charge. So, that's part of the qualification process for this as a business charge. But then I guess we're talking here, guess is the wrong word, what we're talking about here is the eligibility track we had at the start. Is it eligible? If it's personal spend, it's not eligible, it's personal spend. Whether or not it's reimbursed by your employer, that's between you and your company's expense policy.

Jean Dion:

Yeah. So, this ties back actually to even how your policy's written within the organization and what the company's willing to provide and not provide. So, it kind of brings me to a point of thinking about how companies prepare for this type of a service. So we've talked about the risk, we've talked about the data mining, we've talked about the differences in data and how we really need that brain. You talk about the brain, but that it's truly what artificial intelligence is. It's that brain that learns as we do and is able to identify in a more automated fashion what we need to be looking at.

So when teams are preparing for this, are they tying it to how they write their general procurement and travel or employee-initiated spend policies? Are they preparing by updating or reviewing their processes for gaps and seeing how they can clear that together? Are they looking at global tax strategies? Are they looking at all three? What are we talking about when they're preparing for an effort like this?

Dr. Mark Stirling:

Great question, Jean. Thank you for giving me the chance to help organizations understand this. Again, I'll pick up on that word risk. We're here to minimize the worry of risk and to help you control a previously non-scalable process. We're seeing organizations as they approach this looking at it in a few ways. There are some that come to us and they know categorically what they need to do. It's about understanding and controlling the data. They're looking for our tool to help them not just remove all the people from this process and their complexity, but also provide the insights that they need to modify their policy, to modify their behavior.

They'll come to us understanding they've got a human risk, they've got a cost, they may be overpaying and want to reduce that, and so they tend to come in with a deploy the service as it stands. Let's deploy our current practices in there, and then you do the fine-tuning after the tool is in place, because it's the tool that gives you the insights that you need to make those changes.

 

Well, I think what's also interesting in this world of benefits, which is increasingly becoming talked about as a concern as organizations are seeing that the processes aren't scaling. Now, we would advise our clients to go and just take a look at the expense data today. Pick a sample, a few hundred expense reports and take the time to go through them and understand what is in there.

 

Just make a note in your ledger each time you come across a receipt that you don't understand the position of. Is it taxable? Is it not? Should it have a benefit charged to it? Should you reclaim the VAT? Let that process guide you on the challenge that you might be facing, and therefore how we can help you to go through that.

 

Our own analysis has shown, and the data that we're processing on behalf of our clients has shown that as much as 23% of expense reports have the tax information in them that's wrong or potentially wrong that would need a level of scrutiny to go through. Not saying the whole report is wrong, but there might be a line or two that's in there. That's one of the things we're seeing our clients doing to try to understand how to go through this process, looking at their data, understanding what's in that data and then coming to us to ask us to see how we can help.

Jean Dion:

Yeah, and when I think about it, I think about to your point, that whole idea of examining the data and understanding what your process looks like. I also think about it behaviorally and thinking about how are we training our employees around the process itself and what can we do to improve that, so doing a little bit of gap analysis there. That whole idea don't throw away your receipts, or taking a look even at, if you are looking to reclaim something, identifying what you're losing if you're only taking in receipts that are $100 or more in your currency. Do you need to lower that in order to gain on your VAT reclaim?

 

I also think about some of those organizational things and taking a look at your current process to think about what you already have in place for controls and where the gaps in your controls are, and where an automated tool like a Blue dot tool could come in and close some of those gaps for you. I always go back to that biggest risk, that manual work being the biggest risk.

 

One thing that I might recommend to our Concur customers. If you have tax tables that you've got in your system, think about the last time you updated them, how often or frequently you're updating them, and who's required to update them. This might be the first place to look to ensure that, from a compliance perspective and from a gap analysis perspective, that you've got all your bases covered, or that you can identify some of the gaps that are happening that would demonstrate a need for something like an automated solution. That's a lot of work on those tax tables, and I think that manual work, as Mark has highlighted earlier, comes with a lot of risk, because every human is, well, human, and that's how we are.

Jean Dion:

Mark, I want to thank you. It's been a pleasure to talk to you. Is there anything that I haven't covered or anything that I haven't asked that you're dying to share with the audience?

Dr. Mark Stirling:

There's one thing actually that you've caused me to think of based on what you were just saying. You're absolutely right about the tax tables. I've seen to my own personal experience so many times the organizations have deployed them and left them in place, breathe a sigh of relief and found years later they've not been updated. Remember I mentioned hundreds of hundreds of changes.

 

But I'd like to think of it in this way. Employees, all of us want to do the right thing by our employer when it comes to these processes, but we've got to make it simple for them. I've talked about and you've talked about having the insights and the controls, the first thing that we'd encourage our clients to do once they've deployed the tool is to simplify the process for the employee.

 

If you don't need to ask them for quite so much data anymore because the tool's doing that for them, take all that off. Make it as simple as possible and then let them focus on the two or three things you really do need them to get right. If you're at a meal and there are other people at the table with you, we need to know who they are. Are they employees, business guests, family? That has an impact on the tax handling. So simplify it so that the things you do need them to do is easier for them to do it, because at the end of the day, happy employees are what most travel programs are trying to accomplish.

Jean Dion:

Yeah. Yeah, well, I love the whole idea of easing up on the employee experience and making it simpler, but still driving compliance. That solves so many business outcomes, my mind is reeling now. So, thank you for your insights and thank you for sharing all this with me. I have a better understanding of that tax world, and I'm hoping that everybody in the audience does as well.

Jean Dion:

I want to thank everybody for listening in. If you have any further questions or would like to get more information about the Blue dot platforms or the Concur platforms, please go ahead and visit our SAP Concur website. We'd love to see you there and answer your questions if you have any. So on behalf of our SAP Concur Conversations and our guest today, Dr. Mark Stirling, I'd like to say thank you and have a great day.