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.
- This being said, we would like to point out the following points where we see need for revision.
- The new requirements will most likely be more burdensome and costly for SMEs to comply with. The two-day deadline for invoicing cross-border transactions is a significant change and many SMEs may need to change their internal business systems to deal with the two-day deadline. Changes to accounting systems, the purchase of additional third party services and staff training for the new procedures and systems will entail higher costs, affecting SMEs more heavily.
- In the proposed article 24i, there need to be safeguards for businesses to be able to correct faulty information provided by mistake, without the risk of having their VAT identification in the central VIES invalidated, with possibly far reaching negative consequences. The VIES system should provide for opportunity for businesses to, upon request, within reasonable time correct faulty or missing information.
- The scope of the processing of information collected pursuant to regulation 904/2010 is potentially very broad. The centralisation of this information in the VIES needs to be coupled with the necessary safeguards for businesses to be able to give additional information in cases where co-processing of information from member states may lead to erroneous decision because of faulty data in national tax administrations’ records. – The Commission and Council should not push for harmonisation of national rules regarding invoicing in purely national B2B transactions. This should be left to member states and fundamentally be a contractual issue between businesses.
Source ec.europa.eu
Input by other organizations into the public consultation
- EESPA
- InHouse Tax Forum (Belgium)
- Italian Banking Association (ABI)
- ETNO/GSMA
- DATEV eG
- Siemens AG
- Sovos
- EuroCommerce
- Inter IKEA Group
- FedEx Express
- IDW Institut der Wirtschaftsprüfer in Deutschland e.V.
- EU Travel tech
- Business Europe
- MDDP
- PwC
- TEI
- EFAMA
- INDEPENDENT RETAIL EUROPE
- Finnish Commerce Federation
- DIGITALEUROPE
- ETAF
- International VAT Association
See also – The Library of VAT in the Digital Age (VIDA)
Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE
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