Input into the public consultation of the European Commission on ViDA: INDEPENDENT RETAIL EUROPE

Independent Retail Europe is the European trade association that represents groups of (SME) independent retailers in the food and non-food sectors. We bring together 23 groups and associations and their over 417.800 independent retailers, who manage more than 753.500 sales outlets in Europe, with a combined retail turnover of more than 1.320 billion euros and generating a combined wholesale turnover of 513 billion euros. This represents a total employment of more than 6.500.000 persons.
Independent Retail Europe welcomes the opportunity to submit comments on the Commissions proposal VAT in the Digital Age. The package proposed will have wide implications on the invoicing systems (and related data infrastructure) of groups of independent retailers and SME retailers.
We therefore have several comments on the following aspects of the proposals:
- 1) We support the extension of the one-stop-shop and of the deemed supplier rule (in cross-border B2B contexts) and the proposal for a single VAT registration system. Clarification of the conditions of application of the reverse charge should be provided.
- 2) The generalisation of e-invoicing must make possible the continued use of existing EDI standards (e.g. EANCOM® and SAP IDoc). Their mandatory replacement by a new single EU standard would hit hard the retail ecosystem. The two-day deadline for e-invoicing is unrealistic for SMEs and should be replaced by a 30-day deadline.
- 3) The end of summary invoices create major issues for (cooperative) groups of independent retailers and for SME retailers, as it will lead to increased accountancy costs and administrative burdens.
- 4) Digital reporting on a transaction per transaction basis would impose disproportionate burdens on SMEs.

You will find attached a detailed explanation and position on these aspects and their importance for groups of independent retailers and SME retailers across Europe.

Source INDEPENDENT RETAIL EUROPE

Input by other organizations into the public consultation