Review of the VAT rules for financial and insurance services

Dutch pension funds are strongly committed to deliver pension services on behalf of and in the interest of those who work in the Netherlands, either living in the Netherlands or any other Member State. They seek for the lowest cost and the appropriate investment policy (maximizing risk-adjusted returns) and structure their activities according to these objectives (either through insourcing or outsourcing).

EFAMA is grateful for the opportunity to comment on some of the messages included in the European Commission's roadmap on the "Review of VAT rules on financial services". Our comments cover the following sections of the roadmap: - Section A (Box1 - Problem the initiative aims to tackle: the lack of tax neutrality) - Section B (objectives and policy options) - Section C (Preliminary Assessment of Expected Impacts) -…

Insurance Europe welcomes the possibility to comment on the Roadmap/Inception Impact Assessment for the review of the VAT rules for financial and insurance services. We believe that an effort is required to harmonise VAT rules across Europe, establish a level playing field on VAT for all financial services providers, create legal certainty and ensure that European VAT law is fit and proper for the modern business…

The French Insurance Federation is grateful for the opportunity to comment on the enclosed roadmap for a review of VAT rules applicable to financial and insurance services. The industry fully supports the initiative for a global review of current applicable VAT rules.

The Swedish Bankers’ Association (SBA) welcomes the initiative from the European Commission regarding the review of the VAT rules for financial services and appreciates the opportunity to comment on the Roadmap/Inception Impact Assessment.

First of all, it seems to me essential to distinguish between the various so-called financial activities. The following comments concern the insurance sector. 1- The abolition of the exemption In the insurance sector, if the abolition of the exemption could be favourable and promote VAT neutrality, it is on condition that VAT replaces the other turnover taxes borne by the final consumer.

Filed in French · English published by the European Commission

General comments: We welcome the EU Commission's initiative to evaluate the EU VAT rules for financial and insurance services. As comprehensibly presented in the now published "Combined Evaluation Roadmap/Inception Impact Assessment" (short: CER/IIA), the following issues in particular - the lack of VAT neutrality, - the regulatory complexity of the regulations and - the legal uncertainty caused by different…

The private equity industry welcomes the European Commission's initiative to assess the relevance of the current VAT rules for financial and insurance services, notably in the light of developments in the sectors and recent case law challenging practices allowed by most Member States.

Read attached PensionsEurope's complete feedback. In summary: PensionsEurope supports the EC’s objective to simplify the life of taxpayers operating in the Single Market and we welcome the review of the VAT rules.

The EACB welcomes the modernization of the VAT treatment of financial services as the existing regulations are out-of-date and do no longer reflect current practices in the financial sector. The current situation leads to legal uncertainty and an unbalanced level playing field and thus a lack of neutrality.

BIPAR welcomes Europe’s objectives set out in the Commission Roadmap to clarify the VAT rules for the financial and insurance services where it is necessary. BIPAR is of the opinion that, when considering changes in the VAT treatment of insurance services, it is important to take into account the insurance premium tax (IPT) which varies from one Member-State to another.

The VYV Group (Harmonie Mutuelle, MGEN, MNT, MGEFI, Mutuelle Mare-Gaillard, SMACL Assurances, etc.), established in 2017, is the 1st mutual health and social protection actor in France. All the components of the group and their 45 000 staff, protect around 10 million people and propose solutions tailored to more than 89 000 health and welfare companies and more than 84 000 legal entities in IARD.

Filed in French · English published by the European Commission

The European Tax Adviser Federation, ETAF, is a European umbrella organisation for more than 280.000 tax professionals from France, Germany, Italy, Belgium, Romania, Hungary and Austria. ETAF thanks the Commission for the opportunity to comment on its Roadmap / Inception impact assessment on the “Review of the VAT rules for financial and insurance services”.

We welcome the initiative taken by the EU Commission to review the EU VAT rules for financial and insurance services. As stated by the Commission in its “Combined Evaluation Roadmap / Inception Impact Assessment” (CER / IIA for short), • the lack of VAT neutrality, • the regulatory complexity of the VAT rules and • the legal uncertainty caused by differing provisions in the EU member states pose obstacles for a…

• EAPSPI supports the initiative of the EU Commission to review relevant VAT rules and see leeways for the clarification of the legal base of VAT exemptions of (public sector) pensions schemes in the EU – but we are clearly against a general abolition of the system of VAT exemptions or relevant VAT exemptions as described as clearly preferable solution of the Commission in the VAT roadmap.

ESBG strongly supports the modernization of the VAT treatment of financial services as the existing regulations are out-of-date and do no longer reflect current practices in the financial sector. This leads to legal uncertainty and a lack of neutrality.

Introductory remarks The Confederation of Swedish Enterprise welcomes the envisaged review due to the fact that many problems arise from the current VAT framework regarding financial and insurance services. The current rules entail increased costs for start-ups and SMEs, different approaches from member states, an unlevel playing field and great complexity.

AMAFI has always promoted actions for the integration of European financial markets. The Commission’s work on a possible revision of the VAT rules on financial and insurance services undoubtedly contributes to this search for greater economic efficiency in favour of an integrated European market for financial services.

Filed in French · English published by the European Commission