VAT package on travel and tourism

The UTPF fully shares the European Commission’s ambition to revise the VAT rules for passenger transport that today create multi-speed taxation within the EU. Therefore, the UTPF wants to convey three key messages to European decision-makers: The VAT exemptions granted to the aviation and maritime sectors in Europe represent a significant distortion of competition between modes of transport within the European…

Filed in French · English published by the European Commission

Booking.com welcomes the opportunity to provide input to the European Commission's call for evidence on VAT applicable to travel and tourism sectors and the European Commissions aims to reform the VAT rules for Travel and Tourism in line with the digital age and the evolving operating models of the travel sector.

Impact on SMEs Small and medium-sized enterprises (SMEs) play a vital role in the European travel and tourism sector, representing a significant proportion of travel agencies and tour operators across the EU. The complexity and inconsistency of the current VAT regime, particularly the application of the TOMS (Tour Operator Margin Scheme), pose substantial challenges for these businesses.

FTO Organised Tourism Federation of Confcommercio represents the Italian organised tourism sector, which includes tour operators, travel agencies, distribution networks and specialised intermediaries. The membership system comprises thousands of businesses that generate a significant proportion of national tourism turnover, both in outgoing and incoming tourism, as well as in business travel, school travel and…

Filed in Italian · English published by the European Commission

The forthcoming reform of the VAT rules applicable to the travel and tourism sectors should reinforce legal certainty, fiscal coherence and competitiveness across the EU transport market. In passenger transport, maintaining the 0 % VAT rate for international services remains justified on both technical and legal grounds, reflecting long-standing international norms under ICAO and the Chicago Convention.

The current VAT mechanism for international coach passenger transport services represents a significant administrative burden for businesses and a real obstacle to the development of intra-Community services, particularly for SMEs.

Filed in French · English published by the European Commission

Submitted by: Christos Stergiou, Founder & CEO, TrueTrips Ltd (BA Economics, Brandeis University; MBA, Stanford GSB; former Chartered Associate, Charles River Associates) Subject: Modernizing VAT Rules for Inbound Tourism Transition from TOMS to Standard VAT with Export Treatment 1.

End of VAT exemptions and preferential regimes granted to aviation. Aviation is one of the most carbon-intensive modes of transport, yet it enjoys some of the most generous tax exemptions in the EU. One of the key exemptions is the Value Added Tax (VAT). Maintaining the VAT exemption keeps air tickets artificially cheap, boosting demand and driving up CO2 emissions.

Please find attached the position of Fiavet Federazione Italiana Agenti di Viaggio e Turismo on the public consultation on the VAT package for tourism and travel. Our contribution with regard to travel agents proposes maintaining the special scheme, known as TOMS, which guarantees a simple system for the purpose of calculating VAT.

Filed in Italian · English published by the European Commission

The rules in TOMS are no longer up to date. They have also been modified by court rulings in such a way that they are almost no longer applicable. I assume that they are no longer comprehensible to the tax administrations.

Filed in German · English published by the European Commission

The International Air Transport Association (IATA) is the trade association representing the worlds airlines, comprising 363 members, including 144 European carriers, and accounting for approximately 85% of global air traffic. Please find attached IATA`s feedback to the call for evidence.

Subject: Maintaining the zero rate of VAT on international maritime passenger transport. European passenger shipping is a strategic pillar of the EU, ensuring mobility, social cohesion, economic activity and geographical continuity, especially for island and remote regions.

Filed in Greek · English published by the European Commission

EPF welcomes the European Commissions review of VAT rules for passenger transport, stressing that current provisions are complex and unfairly favour high-emission modes like aviation due to zero-rating, while making rail less competitive. Despite strong public concern for the environment, cost remains a key barrier to sustainable travel choices.

The companies submitting this contribution are major European operators from different Member States offering free-floating and/or station-based carsharing services in 13 member states. Together, we account for over 60% of the entire car-sharing market in Europe based on absolute fleet numbers. As leading EU operators of car-sharing services, we represent a key component of modern urban and regional mobility.

The VAT system within the European coach sector is deeply fragmented, with huge variations in the way Member States treat these services applying a zero percent VAT rate, a low rate or, in some cases even a high rate (e.g. 0% in Estonia, 8% in Poland and 25% in Croatia).

Our core recommendation is to foster an efficient Single Market, encourage cross-border mobility, and align with environmental goals. The EU should harmonise the VAT treatment of all international passenger transport.

SNCF Group very much welcomes the consultation launched by the European Commission regarding the VAT rules on passenger transport. SNCF Group has been calling for a long time for a fiscal level playing field between the different modes of transport, in particular when it comes to VAT. The difference in treatment between modes gives a clear advantage to the air sector both financially and administratively.

CFE Tax Advisers Europe welcomes the opportunity to respond to the European Commissions consultation on the VAT rules applicable to the travel and tourism sector, and in particular to the Tour Operators Margin Scheme (TOMS). CFE is of the view that TOMS, in its current form, no longer fulfils its original objectives of simplification and fair taxation.

Please find attached CEOE’s official position on the public consultation on the VAT package for tourism and travel. Our contribution emphasises the principles of: Tax neutrality and equal treatment between EU and non-EU agencies. — Voluntary implementation of the special agency scheme (TOMS/REAV).

Filed in Spanish · English published by the European Commission

Businesses continue to find that the scheme provides important and necessary benefits to travel agents. In particular, the schemes provision to keep VAT registrations to a minimum and the simplified VAT declaration supports the VAT administration of travel agents considerably. However, the current rules are often coming into force also for businesses that are not travel agents.

Awaze welcomes the European Commissions efforts to modernise the VAT rules applicable to the Travel and Tourism sector to make these more compatible with the ways in which the travel sectors now operate. To achieve this objective, within the context of the Special Scheme for travel agents, we call on the European Commission to: Ensure a focus on levelling the playing field with non-EU travel agents, whilst keeping…

It is essential to maintain the form of taxation for travel services under the TOMS rules! Ideal is a very wider TOMS scope, but ONLY in the context of a case-by-case opt-out for normal taxation! This means: TOMS should necessarily be conceived as a genuine option to simplify taxation, so that TOMS can be applied to the sale of travel services provided by third parties in their own name and on their own account (=…

Filed in German · English published by the European Commission

CONFEBUS takes note of the opening of a public consultation by the European Commission on the revision of the Value Added Tax (VAT) Directive (Directive 2006/112/EC). The specific objective pursued by the Commission is to evaluate and review the special VAT scheme for travel agents and the VAT rules applicable to passenger transport.

Filed in Spanish · English published by the European Commission

On behalf of Airlines International Representation in Europe (AIRE), please find below our feedback regarding the VAT rules on passenger rules: The VAT exemption for international air transport is rooted in Article 148(b) and (e) of the EU VAT Directive (2006/112/EC), which provides that: The supply of goods for the fuelling and provisioning of aircraft used by airlines operating for reward chiefly on international…

SMAL is grateful for the opportunity to contribute to the Call for Evidence for an Impact Assessment on the Travel and Tourism VAT Package. SMAL is the Association of Finnish Travel Industry, representing Finnish travel agents and tour operators, DMCs, TMCs, MICE operators, OTAs, etc.

ACCKA welcomes the opportunity to contribute to the Call for Evidence for an Impact Assessment on the VAT Package in Tourism sector. ACCKA represents Czech Tour Operators and Travel Agents and other travel businesses, including DMCS or OTAS. We consider the special tour operators margin scheme to be a welcome VAT simplification and should be maintained, but it needs to be reformed.

Filed in Czech · English published by the European Commission

Dear Sir, on behalf of FETAVE (Federación Empresarial de Asociación Territoriales de Agencias de Viajes España), I am pleased to send you our input in the framework of the public consultation on the review of the Special Scheme for Travel Agencies (REAV).

Filed in Spanish · English published by the European Commission

ECTAA welcomes the opportunity to contribute to the Call for Evidence for an Impact Assessment on the Travel and Tourism VAT Package. ECTAA is the European Travel Agents and Tour Operators Association, representing different travel businesses, including travel agents, tour operators, DMCs, TMCs, MICE operators, OTAs, etc.

Please find attached the feedback of European Boating Industry (EBI) to the consultation on the VAT package for travel and tourism. EBI represents the recreational boating industry in Europe. It encompasses all related sectors, such as boatbuilding, equipment manufacturing, marinas and service providers.

Ladies and gentlemen, as a travel service provider focused on business travel, the TOMS regulation is very negative and impeding. The current regulation needs to be revised as a matter of urgency. For the resale of travel services, in this case hotel rooms, normal taxation must be reintroduced as soon as possible. With best Gruss Fritz Zerweck

Filed in German · English published by the European Commission

As the Federal Association of German Incoming Companies (Bundesverband der Deutschen Incoming-Unternehmen e.v./Federal Association of the German DMCS), we are actively discussing the VAT rules. We see the current rules on VAT Travel & Tourism (TOMS/in Germany, Section 25 of the Turnover Tax Act) very cristically and reject the automatic inclusion in segments B2B and MICE. See Annex for a detailed opinion.

Filed in German · English published by the European Commission

1. There needs to be a unified terminology; a clear distinction of definitions and scope of work for each travel service provider. What is considered a travel agency, a host agency, a tour operator, a travel advisor, a travel planner, intermediaries , reisbemiddeling in Dutch and so on. The myriad of terminology but the lack of clarity on the scope of each results in a mess when it comes to VAT rules. 2.

Danish Shipping is firmly opposed to any changes to the current VAT system for passenger transport. The existing framework is efficient, fair, and neutral for both operators and passengers, accurately reflects economic reality, and aligns with the destination principle as well as EU jurisdiction under international law. Any modification would risk creating unnecessary administrative burdens and market distortions.

The TOMS-all-phase gross turnover tax system with input VAT is essential for the simplest possible taxation of all B2C international travel businesses. A TOMS opt-out is mandatory for B2B trips+events. In other words: TOMS should be applied in a comprehensive manner, but ONLY with a B2B opt-out applicable to each individual case, i.e. the option of standard taxation with deductibility of input tax.

Filed in German · English published by the European Commission

From a regulatory point of view, and bearing in mind that this is a harmonised system, it is a good proposal to standardise the operation of a clearly interrelated sector. Improvement aspects: 1.- reduction of the tax rate applicable to the margin. It is unfair that by taxing the reduced rate almost all the services forming part of the journey, the margin does so at the standard rate.

Filed in Spanish · English published by the European Commission

From Air Europa, as a Spanish airline committed to connectivity, economic development and sustainability, we are strongly opposed to the European Commission’s proposal to apply VAT on intra-European flights. We consider that this measure would have negative consequences in multiple areas: (A) Loss of international competitiveness, especially vis-à-vis non-EU operators who would not be subject to this tax burden.

Filed in Spanish · English published by the European Commission

1. Simplification of margin calculation problem: At present, the margin has to be calculated for each individual service. This creates a heavy administrative burden and often leads to imprecise results. Argument: Choosing margins at group or aggregate level would significantly simplify the process, reduce sources of error and free up resources that can be used more efficiently. 2.

Filed in German · English published by the European Commission

My points: + Negative margins must be possible again + I must be able to ‘compute’ all trips to a given country, each trip is very bureaucratic + certain costs cannot be charged, but this is not a living one: Displays/other promotional activities on a specific series of identical group dates. Or a face-to-face on-site advertising event, with an evening programme – this is also good for travellers?

Filed in German · English published by the European Commission

Individual margin taxation represents a very significant increase in financial accounting, but not more tax fairness. In practice, a tour manager or coach is not available to a traveller for 1/15 or 1/23, but for the travel group as a whole. For the above reasons, the possibility of group margin taxation should be maintained. There should be an opt-out for corporate and business-to-business travel services.

Filed in German · English published by the European Commission

With regard to point two, VAT rules for passenger transport, we would like to make the following comments: The current VAT framework gives international air and sea transport structural benefits that disadvantage rail transport: tax exemptions for input services in air and sea transport create a cost advantage over rail transport (for which there are no comparable tax exemptions for input services).

Establishing the individual margin for groups travelling together is an additional effort. It takes longer for us to receive the final statements of the service providers, as it is likely that there is also a shortage of staff or a greater administrative burden.

Filed in German · English published by the European Commission

The current VAT treatment of passenger transport by coach shows considerable disparities between the Member States of the European Union. While some countries apply the standard rate, others opt for reduced rates or even exemptions.

Filed in Spanish · English published by the European Commission

Good afternoon, The scheme for taxing travel agents on the margin is not bad in principle, but its application is difficult. Two simplifications would be welcome: — be able to declare and pay VAT in respect of a period of time as a whole and not per stay: margin for the period = total customer receipts for the period over all trips – total of supplier invoices received during the period all trips combined; — be able…

Filed in French · English published by the European Commission

CEOE’s contribution to the public consultation on the revision of the VAT framework applicable to air transport and tourism Desde CEOE, representing our member organisations, including the Air Line Association (ALA) and the International Air Transport Association (IATA), expressed our opposition to the European Commission’s proposal to apply VAT on intra-European flights.

Filed in Spanish · English published by the European Commission

Our company, TEST GmbH and Co. KG has been on the market for 36 years. Our core business includes various services around international fairs at home and abroad, mainly hotel reservations. The hotels are purchased by us on our own account and sold on to our customers. The selling price includes either a margin or the margin is invoiced separately in the context of an intermediary.

Filed in German · English published by the European Commission

To me it seems completely reasonable that travel agents pay VAT on their commissions. Like any other service provider, you add extra value to travellers and this extra value has to be taxed accordingly. The current legislation works very well, is easy to imply and impossible to evade.

I am a one man show based in Germany offering customized tours and guide these myself. As most of my tours are outside of the EU my margin would be exempt from VAT. Due to guiding the tours myself I have to pay VAT from my margin. This is a huge disadvantage to the bigger companies which hire guides and only have to pay VAT on the tour guide portion.

The zero VAT on maritime passenger transport, including the chartering of commercial yachts, is a sustainable and simple tax relief measure, but the resulting support for the sector has had a direct impact on the share of GDP, employment and seasonal employment, taxation and social security.

Filed in Italian · English published by the European Commission

The current VAT treatment of passenger transport by coach varies significantly across EU member states. While some apply standard rates, others offer reduced or zero rates. This fragmented approach imposes a disproportionate administrative burden on the sectorparticularly for operators active in multiple countries.

The VAT for passenger transport by coach varies by EU country. Some countries apply a high VAT rate, others a low rate, and some even a zero rate. For the sector, the different systems also pose a heavy administrative burden. The sustainable nature of bus travel argues for a zero VAT rate. Coaches have a high occupancy rate and therefore very low emissions per passenger kilometer.

Ladies and gentlemen, we would like to draw your urgent attention to the need for a revision of the margin tax scheme under the VAT Directive. The current design is neither workable nor competitive for many companies, especially in the B2B sector.

Filed in German · English published by the European Commission