Allegro supports the goal of modernising current taxation rules in the view of digital economy developments, establishing a level playing field and ensuring that digital companies are fairly contributing to the societies where they do business. The Roadmap and OECD discussions one the matter provide for opportunity to achieve these goals.
EU consultation
Digital Levy
35 submissions from 35 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 276 submissions on this file. Shown here: the 35 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
29 submissions from industry — companies and their trade associations — against 3 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 9.7 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
- 19 of 35
- in the EU Register
- 112
- full-time lobbying staff
- €15.8M+
- declared costs a year
- 93
- EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 12 Apr 2021 — it ran from 18 Jan 2021.
- Policy area
- Taxation & trade (DG TAXUD)
- Where it stands
- Awaiting adoption
- Adoption expected
- 30 Jun 2021
How it got here
- Impact assess incep11 Feb 2021
- Public consultation12 Apr 2021
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Prop dir.
Showing 25 of 35 submissions.
The problems of the initiative for an EU Digital Levy aims to tackle are the same that are at the basis of the work performed in the context of OECD BEPS action 1 and the latest OECD pillar 1 blueprint and of the EU DST proposal that was first issued in March 2018.
IMPALA - Independent Music Companies Association
· · filed 11 Feb 2021 · source
IMPALA represents over 5,000 European independent music companies, which account for more than 80% of all new releases and 80% of the sector's jobs. To be fit for the digital age, the EU has to revise its rules to ensure the European market is a place where companies compete on fair terms.
Transfer Pricing Services |TPS
· · filed 11 Feb 2021 · source
Thank you for the opportunity to present our feedback. In our opinion, continuing with the digital levy initiative is likely to bring more negative than positive results for European businesses and consumers at the moment.
The European Commission has published an Inception Impact Assessment to receive feedback about a so-called Digital Levy to be introduced as a legislative proposal later in 2021. Following the Special Meeting of the European Council on July 21, 2020, the head of States and governments of the European Union suggested joint recovery efforts from the Covid-19 crisis.
Booking.com takes note of the Commission’s intention to explore a digital levy as an “own-resource” for the purposes of recovery from the Covid-19 crisis and to support a more stable medium-term outlook. While work on this initiative is still at very early stages, it cannot and should not be seen in isolation from OECD efforts and national initiatives on digital services taxes (DST).
ActionAid International
· · filed 11 Feb 2021 · source
ActionAid welcomes the EC’s commitment to ensuring fairer taxation of the digital economy. Big tech companies are clearly not paying their fair share of tax, neither in the EU or in developing countries where tax revenue is desperately needed to pay for gender responsive public services, including basic services such as education and health care.
Federation of European Publishers
· · filed 11 Feb 2021 · source
The Federation of European Publishers welcomes the opportunity to provide feedback on the roadmap on a digital levy. We fully support the Commission's to design a modern, stable regulatory and tax framework to appropriately address the developments and challenges of the digital economy.
Hi there - Please find attached a response from Deliveroo. Best wishes and please don't hesitate to be in touch with any questions. Nick Hargrave Public Affairs Director, Global Deliveroo, The River Building, 1 Cousin Lane, London, EC4R 3TE deliveroo.co.uk | Facebook | Twitter | Instagram
AMETIC has fervently defended that the fiscal challenges derived from the globalization of the economy should be debated and agreed upon at the international level, within the Organization for Economic Cooperation and Development (OECD), avoiding unilateral solutions that place Europe in a position of clear competitive disadvantage, reducing the interest to attract investment and penalize innovation and business…
The European Association of Cooperative Banks (EACB) gladly takes the opportunity to comment on EC roadmap consultation on the taxation of the digital economy following its comments on the OECD Pillar I and II consultations on the same issue. The EACB welcomes the EC plans on the taxation of the digital Economy.
CIMA is part of the Association of International Certified Professional Accountants alongside the AICPA. The taxation of digital transactions in a cross-border context presents several challenges to the concepts of the right to tax and the allocation of profits between countries.
Insurance Europe welcomes the possibility to comment on the roadmap for the introduction of a digital tax to address the issue of fair taxation of the digital economy. Key points - While data is important for insurers and reinsurers, and they use data from different sources, (re)insurance is not a highly digitalised business model.
To make the tax system suitable for the digitalised economy, EuroCommerce calls for the modernisation of existing international tax rules, consistent with the following principles: Fair - A modern taxation system should be channel-neutral and operate equitably across industries and between different forms of business activities and business models.
Interactive Advertising Bureau Poland (IAB Poland) welcomes the opportunity to contribute to the European Commision’s consultation process on introduction of modern, stable regulatory and tax framework to respond to the developments and challenges of the digital economy. Attached we present our position paper
Uber thanks the European Commission for the opportunity to provide comments on the Inception Impact Assessment for the proposed Digital Levy. Uber has been, and will continue to be, an active participant throughout the global digital taxation debate and has provided key recommendations regarding the design of a global solution.
Europex, the Association of European Energy Exchanges, supports the Commission’s overall objective to ensure a fair taxation of the digital economy in line with the wider G20 and OECD discussions and welcomes the opportunity to comment on the scope of the initiative.
While acknowledging the consultation for a fair and competitive digital economy Fecc would like to raise the following points: 1. On the scope and definition of digital activities/transactions or companies subject to the initiative - Fecc welcomes the initiative of the Commission and the national Competent Authorities to further promote digitalisation within the EU, provided that it is in accordance with the…
Ecommerce Europe, the European Digital Commerce Association, welcomes the opportunity to provide constructive feedback to the European Commission’s inception impact assessment (i.e. roadmap) on the introduction of a European digital tax called “a fair & competitive digital economy – digital levy”, which was published on 14 January 2021. Please refer to the detailed Position Paper attached for further information.
ESBG welcomes the opportunity to comment on the EC’s Roadmap. In our opinion, it is most important that a precise distinction is made as to which companies are to be covered by the digital tax. Therefore, this differentiation should primarily be done based on the core business of a company and based on how the business is conducted.
> > Challenges from the perspective of a European Digital System (EU-D-S): Gisad welcomes the European Commission’s initiative to create a fair and competitive digital economy. The Commission refers to G20 and OECD level initiatives to achieve a world-wide digital release. A separate EU tax makes sense only if it supports the specific objectives of the EU.
Filed in German · English published by the European Commission
CCIA strongly supports efforts at the G20/OECD-level to reform the international corporate tax framework. This remains the optimal forum to address tax challenges linked to the digitalisation of the economy. The renewed U.S. and EU support for this historic undertaking holds the promise of developing a durable global tax reform.
In this paper, eu travel tech sets out its initial views on the possibility of the EU applying a digital levy to digital companies, based on the European Commission Inception Impact Assessment. eu travel tech acknowledges that today’s world economy has been fundamentally transformed, with digitalisation enhancing and permeating all sectors.
Prosus, an EU-headquartered, global consumer internet group and one of the largest technology investors in the world (www.prosus.com), welcomes the possibility to contribute to the design of a modern, stable regulatory and tax framework for the digital economy in the EU. We strongly support the aim to reach a global, profit-based solution to the challenges arising from the digitalisation of the economy.
Confederation of Industry of the Czech Republic
· · filed 8 Feb 2021 · source
Opinion of the Confederation of industry of the Czech Rep. (Inception impact assessment): We prefer the solution including all crucial countries which represents consensus at the OECD level. OECD consensus represents a relevant effort to modernise the tax system and to adapt the current tax system to the structure of the economy where new forms of digital business appeared (and for these new forms of business the…
The International Union of Economists and Managers in the EU countries
· · filed 5 Feb 2021 · source
Digital Levy The rapid development in computer technology world, networking and applications imposed a new way of gathering information, classify it and use it. It was a must to think of a new steps relates to Europe digital future after 2020, that was preceded by the search for a global solution that could support the international reform in the taxation framework for companies to address some of the challenges…
Please find attached comments of ACT | The App Association (Transparency Reg. # 7202951387754) on the European Commission’s Roadmap "‘Digital Levy Legislative Proposal". Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 7202951387754) Rue de Trèves 45 B-1040 Brussels
European Economic Chamber, Nepal
· · filed 22 Jan 2021 · source
Having a Digital Levy no doubt is important for a fair Global Transaction. The current trend of avoiding the taxes by establishing the Digital Company in tax havens or low tax regimes creates unfair competition to the domestic Digital Companies, in particular the SME. I strongly feel that there should be a common understanding between the trading nations on levy to be paid to the country where the delivery happens.
Chronos Consulting, s.r.o.
· · filed 21 Jan 2021 · source
We are continuously drawing attention to the fact that national digital companies established in Member States are subject to a different effective level of taxation than global competitors operating on the Digital Single Market from countries outside of EU or from specific member states.
A digital levy will contribute positively to Europe's social, economic and strategic autonomy interests, as well as to social cohesion and more employment. A study of EIT Digital, executed by Digital Enlightenment Forum: Digital Transformation of European Industry is attached in its short form.
I manage a digital distribution platform for video games, based in France. As such, we do away from VAT collection in the EU to the Moss on the basic principle of our end users "localisation. This basic tax collection is currently not respected by many many players located outside Europe (mainly on Hong Kong or Arabia) which are in the same time ripening the European market and their customers.
Filed in French · English published by the European Commission
Seznam.cz, a.s.
· · filed 20 Jan 2021 · source
Long-term attention is drawn to the fact that national digital businesses established in Member States are subject to different effective levels of taxation than global foreign competitors operating from other EU Member States or third countries. In the digital environment, more than elsewhere, the establishment of a digital business in no way affects the availability of its users and customers.
Filed in Czech · English published by the European Commission
ZDSS - Slovenian Chamber of Tax Advisers
· · filed 18 Jan 2021 · source
With the new initiative (original EU tax), the Commission has a nice opportunity to: 1. It shows how the rights of tax payers should be protected in the light of the EU Charter of Fundamental Rights (Articles 51 and 52) and the Code on the Rights of Tax Payers recommended by the EU and 2. It shall also ensure that it also regulates the PROCEDURE for respecting the rights of taxpayers 3.
JFMO SERVICIOS EN INTERMEDIACIÓN PÚBLICA
· · filed 18 Jan 2021 · source
Is it fair to pay more taxes in a digital economy? Every economic entity is taxed according to the laws of each country. In some countries, taxes are paid on income, at the value added to the asset Excise duties on production and services, creating an unfair tax burden. In short, too much and abuse.
Filed in Spanish · English published by the European Commission
SMEunited - Crafts and SMEs in Europe
· · filed 15 Jan 2021 · source
As regards the introduction of a digtial levy, SMEunited supports the activities taken at international level (OECD) and supports own initiatives at EU level only, if the efforts of the OECD fails. In such a case, action at EU level is necessary to avoid different solutions at national level and distortion of the single market.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.