Input into the public consultation of the European Commission on ViDA: EU Travel tech

The short-term rental (STR) market is among the most dynamic aspects of Europes tourism sector today. Over the past years, STRs have come to revolutionize the way many Europeans travel. Platforms engaged in the intermediation of STRs have played a significant role in the trend, providing consumer transparency and convenience to an otherwise opaque market. This has benefited both consumers and many STR hosts. eu travel tech recognizes the need to adjust and modernize EU tax legislation in light of these developments.

A step in this direction was taken with the 7th revision of the Directive on Administrative Cooperation and the Central Electronic System of Payment Information. Our members fully support the objective of combating tax fraud and are committed to supporting authorities in the enforcement of VAT legislation wherever reasonable.

Nonetheless, we are concerned about certain elements of the VAT in the digital age (ViDA) package of proposals as presented by the European Commission, particularly the VAT deemed supplier regime and its possible application to platforms active in the STR market and passenger transport services.

The proposed regime would introduce significant compliance costs, negatively affect VAT and STR channel neutrality and disproportionately impact SMEs and consumers engaged in the rental of short-term accommodation. eu travel tech wishes to be a constructive partner to policymakers, facilitating the development of legislation which is proportionate and fit for purpose.

The attached paper is thus split in two sections: firstly, we outline our general views on the concept and justification of the deemed supplier regime and second, we raise concrete issues we have identified in the proposals of the ViDA package that we believe would benefit from clarification and improvement. While this paper focuses on STR services, the views outlined below also apply in relation to passenger transport services. Please find our full views in the attached position paper.

Source EU Travel tech

Input by other organizations into the public consultation