- EuroCommerce fully supports 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 becoming more resilient to fraud. We believe the VAT in the Digital Age proposal is well placed to embrace digitalisation, and effectively addresses the challenges faced by businesses (and in particular by SMEs) who trade, or have ambitions to trade, across EU borders.
- The key aspects from a commerce perspective are:
- The expansion of the Union One Stop Shop (UOSS) and the introduction of a transfer module allowing businesses to use one single VAT registration to report transfers of own inventory to locations across the EU, as well as the onward sales in those locations. We strongly encourage Member States to reach consensus on this pillar, as it would be a pivotal tool to reduce the need for costly, time-consuming and often prohibitive need for businesses wanting to sell products across the EU to maintain multiple VAT registrations.
- Amendments to the text of the proposal should be in line with the north star goal of reducing the VAT administrative burden for businesses. To achieve this, it is key that there is no (or very limited) negative VAT cash flow impact when businesses opt to report through the UOSS and the transfer module.
- Any newly introduced obligations for businesses and for electronic interfaces facilitating the transfer and/or the sale of goods should be proportional and ensure a level playing field.
- A shift to real-time digital reporting based on e-invoicing for businesses that operate cross-border in the EU and a more harmonised framework for domestic transactions. We acknowledge the motivation to introduce Digital Reporting Requirements (DRR), as they will play an important role in the simplification of the EU VAT system and the fight against VAT fraud. However, such measures need to take into account the substantial bureaucratic burden for companies, in particular for small and medium sized enterprises.
Source EuroCommerce
Input by other organizations into the public consultation
- EESPA
- InHouse Tax Forum (Belgium)
- Italian Banking Association (ABI)
- ETNO/GSMA
- DATEV eG
- Siemens AG
- Sovos
See also – The Library of VAT in the Digital Age (VIDA)
Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE
