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.
The following comments relate primarily to the Digital Reporting elements of the proposals. This is the area which is likely to be most invasive to existing business processes, and most costly to the widest range of taxpayers. Despite that cost, however, we agree with the Commission that the current situation with multiple systems is itself costly and should not be allowed to continue.
If we continue on the path of each Member State introducing its own bespoke Digital Reporting system for VAT we could in theory have twenty seven different systems twenty seven different solutions for essentially the same problem, which is clearly inefficient. Given that alternative the ICC embraces the Commissions proposal to harmonise Digital Reporting.
Whilst that principle is sound, however, we have set out a number of points that we feel require further consideration or clarification to ensure that the DRR proposals achieve the maximum positive effect whilst minimising any additional compliance burden and avoiding disruption to commercial practices.
We would also refer the Commission to the ICCs publication Practice Principles For Implementation of Continuous Transaction, which echoes or expands on the comments herein.
Source ICC
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
- Federation of Swedish Business Owners
- Confederation of Finnish Industries
- MEDEF
See also – The Library of VAT in the Digital Age (VIDA)
Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE
Follow us on
