VAT Essentials: Disbursements, Recharges & Composite Supplies Explained

This session is designed for both VAT practitioners and those new to the subject, offering a structured and practical overview of disbursements, recharges, and composite supplies, areas that frequently sit in the “VAT grey zone”. The training will begin with a concise refresher on core VAT principles, before addressing the often‑blurred distinction between disbursements and recharges, explaining when costs fall within or outside the scope of VAT, and highlighting the strict conditions and documentation required to support the correct treatment.

The session will then turn to composite supplies, focusing on how to identify whether a transaction constitutes a single supply or multiple supplies, and why this distinction is critical from both a VAT and risk‑management perspective. Practical examples will be used throughout to illustrate how economic reality, rather than labels used in invoices or agreements, determines the VAT outcome.

Drawing on real‑world scenarios and recent case law, the training will explore common problem areas—such as cost allocations, wage recharges, and pass‑through expenses, highlighting typical pitfalls and areas where businesses frequently fall into the “VAT fog”. The session will conclude with clear practical takeaways, a compliance checklist, and an interactive Q&A, ensuring participants leave with greater clarity and confidence in navigating these complex and often misunderstood VAT concepts.

The Speaker

Kenneth Cremona graduated with a Master in Accountancy from the University of Malta in 2015. Kenneth joined RSM Malta in 2016, initially working on Income Tax Compliance dealing with clients established in multiple industries including Gaming, Immovable Property, Investments, Pharmaceuticals and Retail. During 2019, he specialised in VAT advisory and was promoted to a Supervisory role within the firm, and as an Assistant Manager in 2021. Kenneth is also a CPA warrant holder and received the Professional Certificate in Taxation issued by the Malta Institute of Taxation in 2017.