Input into the public consultation of the European Commission on ViDA: TEI

Tax Executives Institute commends the Commission’s extensive work on this initiative.
We particularly agree with and welcome efforts to standardize VAT reporting obligations and prevent introduction of uncoordinated variances by Member States.
We also welcome extension of deemed supplier rules for supplies of goods within the EU, which not only simplifies business processes, but also better respects the horizontal neutrality of both EU and non-EU established businesses. The proposed measure whereby platforms would have to account for VAT when they move goods owned by the underlying sellers across EU-borders, instead of the underlying seller, is also appreciated, as it will prevent sellers (albeit largely smaller sellers) from having to register in multiple EU Member States.
With respect to the platform economy, we commend the Commissions efforts to harmonize the VAT treatment of short-term rentals across the EU. In view of minimizing administration and compliance costs, we support the Commission in further streamlining reporting and recordkeeping obligations for electronic interfaces and platforms, ideally by only requesting the same data once.
While TEI members enthusiastically support the above aspects of the Proposal, we do believe additional work is necessary.
As with any undertaking of this magnitude, the devil is in the details, and there remain significant opportunities to further harmonize the European VAT system, increase horizontal neutrality, and eliminate unnecessary administrative burden. To this end, we have identified a number of concerns in portions of the Proposal pertaining to VAT reporting obligations, the Platform Economy, and the single VAT registration. These concerns are listed below and discussed more broadly in the attachment.
Concerning VAT reporting obligations, we urge the Commission to: integrate Intrastat reporting obligations; expand the implementation period for new e-invoicing requirements to a minimum of 18 months beginning on the date that final rules are published; add status of registrations to VIES; adopt a unified method of data transmission; broaden the two-working-day requirement to a minimum period of two weeks; proscribe Member States from requiring additional invoice requirements; allow use of summary invoices in limited circumstances when it is impracticable to match buyer and seller data on a transactional basis; allow flexibility in issuing and reporting credit invoices; consider eliminating the proposed addition of IBAN numbers on invoices; consider adding optional, simplification measures, such as the use of paper invoices, for businesses with gross revenues below a designated threshold; and clarify various terms and concepts noted in the attachment.
Concerning the Platform Economy, we urge the Commission to: conduct further study on the tourism sector before proposing changes; adopt a council regulation to support proposed expansion of the deeming provision to electronic interfaces; align the proposed place-of-supply rules with principles in the OECD VAT/GST Guidelines; expand the OSS to avoid unnecessary administrative burden; resolve unequal VAT treatment for platforms providing the same travel agent services; streamline reporting obligations to avoid creating a barrier for start-ups and innovative companies; and clarify various terms and concepts noted in the attachment.
Concerning the single VAT Registration, we urge the Commission to: reconsider the proposed treatment of supply of second-hand goods, works of art, etc. as Intra-Community sales of goods; reevaluate the benefits of the proposed unique consignment number against the costs and administrative burdens of implementing it; extend the IOSS, OSS, and Single VAT Return to allow for recovery of input-VAT; integrate Intrastat reporting obligations with the special scheme for a businesss transfer of its own goods, and clarify various terms and concepts noted in the attachment.

Source TEI

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