VAT in the Digital Age

We warmly thank you for the opportunity to comment on the Commission’s proposal. The German Tourist House Association explicitly supports the Commission’s efforts to increase tax transparency and combat tax evasion.

Filed in German · English published by the European Commission

The Federation of Swedish Business Owners (Företagarna) wishes to give the following feedback regarding the proposed Council regulation. We acknowledge the need for further harmonised rules regarding VAT in cross-border trade in the single market. The most central aspects of the sharing of information between member states' authorities are necessary to facilitiate simplified VAT handling.

European Automotive Service and Repair Association (EASRA) experts welcome the proposal on VAT in the Digital Age and congratulate the European Commission to update VAT reporting obligations. It does be an important step to adequately combating "carousel fraud" of imported vehicles. Some improvements are still to be brought so that the administrative burden linked with VAT invoice be automatically put in place.

We welcome the opportunity to provide feedback on the European Commission’s proposal “VAT in the digital age”. The Commission’s proposal represents a major step towards a simplified and modernised VAT system in the EU. Our feedback focuses on the uniform VAT registration in the EU, which will be an important simplification for businesses operating in the EU.

Filed in German · English published by the European Commission

The International VAT Association welcomes the opportunity to comment on the VAT in the Digital Age proposals launched by the EU Commission on 8 December 2022. The International VAT Association (IVA), formed in 1994, is the worlds leading non-profit Association of VAT/GST professionals with currently over 180 members covering EU and non-EU countries representing many thousands of businesses and clients, each of whom…

Dear Sir/Madam, We welcome the consultation of the European Commission relating to its proposed package on VAT in the Digital Age published on 8 December 2022. We would like to share hereattached some overarching observations, followed by some more technical comments.

The International Chamber of Commerce (ICC) welcomes the opportunity to provide feedback on the Commissions VAT in the Digital Age proposals published on 8 December 2022. We commend the Commission on its continued commitment to realising the goals of its 2020 Action Plan, of which the VAT in the Digital Age proposals are a significant component.

ECTAA, representing travel agents and tour operators in Europe, welcomes the opportunity given by the European Commission to provide its views on the ViDA package adopted on 8 December 2022, and more specifically the proposed VAT rules for platforms supplying short-term accommodation (and/or transport services), where the underlying supplier does not charge VAT.

The European Holiday Home Association (EHHA), the united voice for short-term rental accommodation in Europe, supports the intent of the Commissions proposal for the VAT in the Digital Age (ViDA), which aims to simplify taxation rules adapted to the digital age, fight tax fraud and benefit businesses.

CFE Tax Advisers Europe broadly welcomes the EU Commissions VAT in the Digital Age (ViDA) legislative proposals which aim to adapt current VAT rules in the EU in light of changes brought about by digitalisation of the economy.

We welcome the opportunity to provide our feedback on the VAT in the Digital Age proposal of the European Commission. We fully support the European Commissions ambition to improve the VAT system through the use of digital tools, reducing VAT-related barriers for cross-border trade in the EU and making the VAT system better for businesses, while also more resilient to fraud.

Independent Retail Europe is the European trade association that represents groups of (SME) independent retailers in the food and non-food sectors. We bring together 23 groups and associations and their over 417.800 independent retailers, who manage more than 753.500 sales outlets in Europe, with a combined retail turnover of more than 1.320 billion euros and generating a combined wholesale turnover of 513 billion…

The BDI welcomes the European Commission's proposal on VAT in the Digital Age (VIDA) to mod-ernise VAT reporting obligations by introducing Digital Reporting Requirements (DRR) by 2028. According to the EU Commission this is an important step to overcome the fragmentation of the European VAT system and to complete the single market by adequately combating fraud using the possibilities of digitalisation.

The Institute for Digitalisation in Tax Law (Institut für Digitalisierung im Steuerrecht e.V., IDSt) is a German non-profit organisation for the fostering of digitalisation in the field of taxes. Our members are wide-spread and come from the Public Sector (including tax administration), academia, business, Tax advisors, and associations.

Ecommerce Europe welcomes the opportunity to provide feedback on the VAT in the Digital Age proposal of the European Commission, which is a big step forward to delivering a simplified and modernised VAT system in the EU. Please find enclosed our comments. Our paper addresses first and foremost the pillar of Single VAT Registration in the EU as this will be a key simplifier for businesses operating in the EU.

FEVITUR, the Spanish Federation of Short Term Rentals Associations, welcomes with interest the legislative proposal on "VAT in the digital age" that we consider should guarantee equal conditions in terms of VAT for all tourist accommodation, regardless of the channel of commercialization As manager of Fevitur, I am sending you the letter signed by Miguel Angel Sotillos, as president of the federation.

The Institute for Digitalisation in Tax Law (Institut für Digitalisierung im Steuerrecht e.V., IDSt) is a German non-profit organisation for the fostering of digitalisation in the field of taxes. Our members are wide-spread and come from the Public Sector (including tax administration), academia, business, Tax advisors, and associations.

Dear Sir/Madam, the Handelsverband Deutschland HDE e.V. would like to thank the European Commission for the opportunity to comment on the proposal for a Council Directive amending Directive 2006/112/EC as regards value added tax rules for the digital age, COM(2022) 701 final, 2022/0407 (CNS) of 8. December 2022. Please find our comments in the attached document Vida – Opinion of Handelsverband Deutschland – HDE e.V.

Filed in German · English published by the European Commission

Founded in 1918, FEDIL The Voice of Luxembourgs Industry (hereinafter FEDIL), is a multi-sector business federation, giving a voice to nearly 700 industrial members, service providers and construction companies and fostering economic activity in Luxembourg.

Members of the Tax Director Network agree in principle with the EUs intentions behind the ViDA proposals. Members have comments on specifics which we summarise here and in more detail attached. E-INVOICING AND DIGITAL REPORTING We recommend the EC reconsiders its proposal not to accept PDF invoices as e-invoices and to remove summary invoices because of the additional compliance burden it will place on taxpayers.

Tax Executives Institute commends the Commission's extensive work on this initiative. We particularly agree with and welcome efforts to standardize VAT reporting obligations and prevent introduction of uncoordinated variances by Member States.

EFAMAs members' concerns are limited to the Digital Reporting Requirements (DRRs) (e.g. electronic invoices) that will be introduced. One of the aims of this DRR element of the proposal is to fight tax fraud (which can be hard to happen in transactions that are VAT exempt).

Bitkom welcomes the Commissions proposal for a directive on VAT rules for the digital age as a meaningful initiative to simplify the current VAT system. In the attached position paper, we elaborate on our considerations with regards to 1) Digital Reporting Requirements, 2) the VAT treatment of the platform economy, and 3) single VAT registration in the EU and IOSS.

Based on e-invoicing, more and more countries are transforming their traditional VAT compliance into a digital transfer of data with the tax authorities. This also applies to those Member States whose different systems cause fragmentation in the internal market and additional compliance costs for businesses operating cross-border. For this reason, the Deutscher Steuerberaterverband e.V.

Filed in German · English published by the European Commission

We appreciate that in the current proposal for a Directive, Article 272(1)(c) of VAT Directive 2006/112/EC exempting taxable persons carrying out only supplies of goods or of services remains unchanged. However, for the financial sector the proposal could be optimised by amending Article 272(1)(c) in such a manner that: - it is not an option for Member States but rather a mandatory exclusion; - it does also apply to…

The short-term rental (STR) market is among the most dynamic aspects of Europes tourism sector today. Over the past years, STRs have come to revolutionize the way many Europeans travel. Platforms engaged in the intermediation of STRs have played a significant role in the trend, providing consumer transparency and convenience to an otherwise opaque market. This has benefited both consumers and many STR hosts.

Dear EU Commission, We thank you for the opportunity to comment on the proposal "VAT in the digital Age" (ViDa). The DGRV - German Cooperative and Raiffeisen Confederation represents both the umbrella organization and auditing association of the German cooperative sector with 19.5 million members in about 5.200 mostly small and medium sized cooperative entities.

See PDF Ci-attached comment note on the proposal for a VIDA Directive from FNFE-MPE, National Forum of the Electronic Facture bringing together the ecosystem in France (more than 200 members) and heavily involved in the implementation of the 2024-2026 reform on electronic invoicing and e-Reporting, interoperability, standards and standards, good practices and international work.

Filed in French · English published by the European Commission

Founded in 2015, the Association pour un Tourisme Professionnel (AToP) is the think-tank for tourism professionals in France. It is committed to working with the sector's economic players and public policymakers to promote the "French art of living and elegance" and create the conditions for the righteous development of the tourism economy. The AToP promotes the quality requirements of the tourism industry.

Please find attached and below feedback on the proposal on VAT in digital age. The European Consumer Electronics Retail Council (EuCER) welcomes the European Commissions proposal on Value Added Tax (VAT) in the digital age. - Reinforced role of online marketplaces in the collection and remittance of VAT - EuCER sees as an improvement the reinforced role of online marketplaces in the collection and remittance of VAT.

As the owner of the IKEA brand and worldwide IKEA franchisor, Inter IKEA Group works together with its franchisees and suppliers to co-create an even better IKEA offer and franchise system that benefits the many. We welcome the European Commissions VAT in the digital age initiative in order to modernize VAT reporting, adapt VAT treatment of the platform economy and facilitate VAT registration and compliance.

EuroCommerce, representing the European retail and wholesale sector, are pleased to provide detail comments on the proposal on VAT in the digital age in the attached document. EuroCommerce welcomes the opportunity to provide feedback on the VAT in the Digital Age proposal of the European Commission.

Sovos welcomes the opportunity given by the European Commission to provide input in a public consultation on the European Commission Proposal for a Council Directive amending Directive 2006/112/EC as regards VAT rules for the digital age (hereinafter referred to as the Proposal).

The French Banking Federation (FBF), in its capacity as a professional organisation representing all banks established in France and comprising 300 member banking companies, of all sizes, French or foreign, appreciates the opportunity to contribute to the European Commission’s work on the draft directive on VAT in the digital era.

Filed in French · English published by the European Commission

Danish Shipping represents the Danish shipping industry, which is one of the largest in the world, contributing to growth and leading the way towards a more sustainable shipping industry. We appreciate the opportunity to provide feedback on The Commission's plan for VAT in the digital age.

DATEV welcomes the EU Commission's initiative to combat VAT fraud and to exploit the opportunities offered by digital technologies. In view of the different digital reporting systems for combating VAT fraud in the Member States, the European initiative is to be welcomed, especially the focus on combating fraud in cross-border cases and the interoperability of the different existing approaches.

Dear EU Commission, We thank you for the opportunity to comment on the proposal VAT in the Digital Age. Siemens AG is committed to promoting digitalization in tax law. We therefore comment attached our position on the planned changes. We would like to emphasize in advance that we welcome the initiative, even if not fully. For us, e-invoicing is the right step into a more digital future.

The European Commission's new rules would require companies operating across member states to report cross-border transactions immediately to comply with real-time digital reporting standards. Blockchain technology can bring efficiencies in VAT collection, reduce verification costs, and improve relationships between governments, potentially reducing VAT fraud by EUR 50 to EUR 60 billion annually.

The Feriehusuddernes Brancheforening thanks for the opportunity to comment on the Commission’s proposal in the field of VAT – VAT in the Digital Age. Our response to the consultation is focused on the part of the package of proposals related to the platform economy in relation to short-term real estate rentals.

Filed in Danish · English published by the European Commission

Since its introduction in 2006, the EU VAT Directive (Council Directive 2006/112/EC) has served to harmonise value-added tax (VAT) within the European Union (EU), providing EU Member States with a common framework and understanding in the area of VAT. Having such an overarching framework in place is essential for European enterprises, many of whom conduct business across the single market on a cross-border basis.

As an accountancy firm specialising in e-commerce, EXCILIO follows very closely developments related to VAT rules applicable to e-commerce and remains particularly sensitive to these issues which have a direct impact on our clients.

Filed in French · English published by the European Commission

Unfortunately, the administrative burden on businesses is again generated instead of reducing them. First of all, a uniform tax rate should be established in all countries in order to ensure that the correct rate is always applied, especially in e-commerce. At present, only the determination of a correct tax rate in an online shop is highly complex (country of the recipient of the invoice vs.

Filed in German · English published by the European Commission

Feedback on EC initiative "VAT in the digital age" We greatly value the European Commission's action plan for fair and simple taxation on whether the current VAT rules are adapted to doing business in the digital age. The initiative indicates that the EC wishes to achieve fair taxation of both online and traditional economic transactions.

Digital B2b Observatory of School of Management of Politecnico di Milano, from 20 years, aims to support business decision-makers in understanding the opportunities that digital tools can offer for the digitization and automation of business processes and business relations, helping to drive the Country system towards more significant and aware digitization through solid empirical evidence and independent areas for…

The initiative to simplify the methods of business identification in the different Member States and to reduce the technical, legal and administrative difficulties faced by SMEs is welcome. These difficulties are linked not only to the need to deal with the tax administrations of individual Member States and the lack of language knowledge, but also to the complexity of the registration rules underlying their…

Filed in Italian · English published by the European Commission

The Deutsches Steuerberaterverband e.V. (DStV) represents some 36 500 professionals, representing more than 60 % of tax advisers, tax representatives, auditors, sworn accountants and professional companies in Germany. The DStV represents its interests in the professional law of tax advisors and accountants, tax law, accounting and auditing.

Filed in German · English published by the European Commission

Onyx CenterSource (“Onyx”) highlights the following, in addition to Part I of the questionnaire brought by the Commission concerning Digital Reporting Requirements (DRR): a. Onyx acknowledges that the Member States have sought to close their VAT gaps through the implementation of DRRs.

Response to the European Commission’s consultation document VAT in the Digital Age The proposal for a revision of the VAT Directive should address the following: · Member States no longer having to ask for an explicit derogation for introducing mandatory e-invoicing for B2B transactions · Define common minimum standards and requirements for digital reporting and e-invoicing across EU member states to avoid…

IMPALA represents close to 6,000 independent music companies across Europe. Accounting for more than 80% of all new releases and 80% of the sector's jobs, they are world leaders in terms of innovation and discovering new music and artists.

The International Air Transportation Association (IATA) is the trade association for the world’s airlines. IATA’s 290 members, of which 67 are based in the EU, comprise 83% of total air traffic. We appreciate this opportunity to submit comments for this impact assessment. Please find in attached document our feedback.

Summitto welcomes the opportunity provided by the European Commission to give input on how technology can be used to reduce administrative burdens while at the same time fight tax fraud. There are various topics on the agenda of the “VAT in the Digital Age” initiative. We will focus on Digital Reporting Requirements (DRR), given our knowledge and experience in this field.

Ecommerce Europe welcomes the opportunity to reply to the call for evidence on the VAT in the Digital Age proposal of the European Commission. Ecommerce Europe fully supports the European Commission’s ambition to reduce VAT-related barriers for cross-border trade in the EU, in particular the work towards a single EU VAT registration.

Delivery Hero welcomes the opportunity to contribute to this European Commission consultation on the “VAT in the digital age” legislative package aiming to bring the EU VAT legislation up-to-date, while fostering a more uniform application of rules across the Member States and preventing fraud.

The Swedish Business of Busses/The Swedish Bus and Coach Federation welcomes the initiative to extend the possibilities for a single VAT registration in the EU. The problem of VAT registration and accounting is a major problem for tourism bus operators at present.

Filed in Swedish · English published by the European Commission

CPME agrees that the current VAT system remains complex and burdensome, particularly for the smallest businesses. Beyond the fight against fraud, it is difficult for small and medium-sized enterprises to take a final decision at this stage. Indeed, the choices made are still too broad to have an overall view of the final devices.

Filed in French · English published by the European Commission

The La Poste Group is a major player in cross-border e-commerce in Europe. In this respect, it has been fully affected by the regulatory measures adopted by the European Commission in the field of taxation since July 2021. It is in this context that he wishes to take part in the debate on potential improvements to the current arrangements by submitting the position note attached. Christophe Pereira

Filed in French · English published by the European Commission

FSB supports the Commission’s objective of ensuring the EU’s tax framework is fit for purpose in the digital age. Our comments relate particularly to the issue of VAT registration in the EU. Under the terms of the new UK-EU trading relationship overcoming issues relating to VAT – and in particular requirements to register for VAT purposes in multiple EU Member States - are one of the biggest challenges facing UK…

I am against digital VAT and I support an immediate end to this measure, as well as the further digitalisation of the COVID-19 vaccination. An immediate halt to both measures. Let’s finally stop here! We know what you want to do with this and who would benefit from it! It does not serve the best interest of the person, but leads us to enslave humanity, to a sick and imageable society!

Filed in German · English published by the European Commission

I can only agree with the letter below! If they prohibit offshore accounts and hedge funds simply to benefit the elite, they regulate pseudo foundations, all in all they will know who they should serve, not the oligarchs, corporations, banks, technocrats, etc. We are people who generate GDP, but we have to pay up to 45 % of taxes on our work, while the above-mentioned maximum of 25 %.

Filed in German · English published by the European Commission

Can only agree with the following! If they prohibit offshore accounts and hedge funds simply to benefit the elite, they regulate pseudo foundations, all in all they will know who they should serve, not the oligarchs, corporations, banks, technocrats, etc. We are people who generate GDP, but we have to pay up to 45 % of taxes on our work, while the above-mentioned maximum of 25 per cent.

Filed in German · English published by the European Commission

A paramount issue to Electric Vehicles charging pertains to the classification of the charging transaction for VAT purposes especially, but not limited to, public recharging point. The recharging activity entails a large number of services far beyond the mere supply of electricity (e.g.

I still see big VAT gap on marketplaces and platform which provides electronic services. New legislation from 1.7.2021 solved only VAT responsible marketplaces for selling physical goods but not electronic services (TBE). I suppose there should be same new legislation for TBE services too. Especially extremly fast growing gaming industry is still suffering because EU wasnt be able to solve this.

I regret this widespread use of digitalisation and digitalisation of all procedures. This requires a large amount of digital equipment for all professionals who are energy-intensive and consume very limited resources (e.g. smartphone materials) and dehumanised all procedures, and humans are replaced by machines, which is very deplorable in terms of life balance.

Filed in French · English published by the European Commission

Technology is a great enabler, but to improve the EU VAT system, technology must be built and used on a modern foundation that reflects current business practices. When designing a digital reporting solution, the following design criteria should be applied: (a) Efficient enabling of automation for both tax administrators and companies, while respecting proportionality between administrative burden and safeguarding…

With over 1 100 member companies, eco is the largest association of the internet economy in Europe. Since 1995, eco has been instrumental in shaping the internet, promoting new technologies, creating a framework environment and representing the interests of its members vis-à-vis politics and in international fora.

Filed in German · English published by the European Commission

Hello, The benefits of new regulation can only be in the direction of simplifying procedures for businesses. To this end, the extension of the OSS system to all cross-border transactions would (probably) be the simplest and easiest approach) to be implemented. Indeed, some B2C transactions are not allowed on OSS.

Filed in French · English published by the European Commission

The digital systems applied to taxation can certainly be very effective both in terms of combating tax evasion and in terms of simplification. However, prior to the use of these IT tools, there should be a policy of uniformity of rules within the European Union, in particular on VAT rates and electronic invoicing.

Filed in Italian · English published by the European Commission

As European Anti Poverty Network Nederland (EAPN NL) we urge you to bring the VAT down to 0% for biological vegetables. This has two reasons. Firstly this good and healthy food can also get available for low(er) incomes and secondly it will promote a change of agriculture. Than we want to use this opportunity also to aks you to start a change in taxes that brings profit for all.