date of receipt: 28 April 2023
To: Council of the European Union
(1) appreciates the existence of online platforms, but there are some technical reservations
regarding the introduction of the buyer-reseller regime for platforms and the definition of short-
term housing rental based exclusively on the number of days;
(2) supports that:
a) these changes regarding electronic invoicing and digital reporting of transactions, but
considers that the reporting systems for internal transactions must be adapted according to the
needs of the member states and must not be limited only to the requirements of the reporting
systems for intra-community transactions;
b) the steps regarding the improvement and clarification of the legislation in the field of
VAT, including with regard to the single registration for VAT purposes, in order to reduce the
administrative burdens implied by the fact that non-established taxable persons are obliged to
register for VAT purposes in other member states where they owe the tax.
(3) draws attention to the fact that:
a) the introduction of the presumed supplier? rule in the passenger transport services
sector in the platform economy would mainly affect European passenger transport platforms, as
they represent the vast majority of digital platforms operating in the EU, especially compared to
large non-European platforms;
b) the proposals could affect drivers who have low incomes and currently do not owe VAT,
given that the digital platform (as the alleged supplier) will charge VAT, without the right to
deduct, and the additional VAT on the charged journey of the platform will be indirectly
transferred to the driver or covered by the passenger, by increasing the price of the trip.
Source: europa.eu
