Comparative Analysis of GST Frameworks

This research paper undertakes a comparative analysis of the Goods and Services Tax (GST) frameworks of Australia, Canada, and the European Union (EU) to identify actionable insights for improving India’s existing GST system. While India’s GST regime represents a landmark shift towards indirect tax unification, it continues to face challenges including multi-rate complexity, compliance burdens, and inter-governmental fiscal disputes. In contrast, Australia’s single-rate, digitally integrated GST model, Canada’s dual-tier federal–provincial structure, and the EU’s harmonized yet flexible VAT system offer diverse lessons in simplicity, administrative coordination, and cross-border taxation. The study analyses structural features such as rate design, compliance systems, revenue distribution models, and taxpayer experience. Through doctrinal and comparative legal methodology, it evaluates the effectiveness, efficiency, and equity of each framework. The findings suggest that adopting simplified tax structures, enhanced digital infrastructure, and more transparent inter-governmental coordination could substantially improve India’s GST architecture. The research contributes to the discourse on tax reform by offering policy recommendations grounded in international best practices tailored to India’s federal context.