Fiscalis Workshop in Madrid: Clarifying VAT Complexities: Deemed Supplier Regime, Platform Roles, and Chain Transactions

The main topic of the Fiscalis Workshop held in Madrid on 17–18 September 2025 was the future of VAT in the EU, with a particular focus on drafting explanatory notes for upcoming VAT legislation. Participants discussed how to interpret and implement complex VAT rules—especially those affecting digital platforms, the deemed supplier regime, and cross-border transactions—to ensure clarity, consistency, and practical application across Member States.

Shaping the Future of VAT: Key Outcomes from the Fiscalis Workshop in Madrid

From 17 to 18 September 2025, the European Commission hosted a pivotal Fiscalis Workshop in Madrid, bringing together stakeholders to discuss the evolving landscape of VAT policy across the EU. The event, coded FWS/047/001, focused on refining legislative guidance and fostering collaboration between Member States, businesses, and VAT experts.

Broad Participation and Collaborative Format

The workshop welcomed approximately 80 participants, including representatives from 27 EU Member States, members of the VAT Expert Group (VEG), and voices from the platform economy. The European Commission facilitated the event, which was structured around six working groups. Each group tackled specific VAT-related topics, with daily presentations summarizing their findings.

Core Objectives and Discussions

The primary aim was to shape the content of forthcoming explanatory notes on VAT legislation. Participants were encouraged to highlight practical difficulties and ambiguities in current rules, ensuring that future guidance would be both comprehensive and actionable.

Discussions centered on several complex and interrelated issues:

Deemed Supplier Regime (DSR): Participants debated its application, optional nature, and interaction with Article 28 and the Tour Operator Margin Scheme (TOMS). The roles and responsibilities of digital platforms under DSR were also scrutinized.
SME Exception and Facilitation Fees: The treatment of small and medium enterprises and the handling of facilitation fees in platform transactions were reviewed, alongside the implications of Article 46a.
Implementing Regulation and Timing: Questions arose regarding the interpretation of the Implementing Regulation and the timeline for adopting related rules and legislation.
Complex Transactions and Transparency: The workshop addressed the challenges of chain transactions and their alignment with general VAT principles. Calls for greater transparency from Member States underscored the need for harmonized application across the EU.

Points of Debate

Several issues sparked deeper debate, including:

Whether the deemed supplier regime should be optional or mandatory.
How to clearly delineate between DSR, Article 28, and TOMS.
The treatment of complex, multi-party transactions.
The consistency of national practices with overarching EU VAT rules.

Next Steps and Drafting Process

Following the workshop, attendees were invited to submit additional comments within two weeks. The European Commission will begin drafting explanatory notes, with the first draft expected in the first quarter of 2026. Member States and business stakeholders will have further opportunities to contribute during the drafting phase, ensuring that the final guidance reflects a balanced and practical approach.

Conclusion

The Madrid workshop marked a significant milestone in the EU’s ongoing efforts to modernize VAT policy. By fostering open dialogue and integrating diverse perspectives, the event laid the groundwork for clearer, more effective VAT legislation that supports both compliance and innovation in the digital economy.

Source Presentation – Outcome Fiscalis Madrid