SUMMARY
Executive Summary:
The European Union’s “VAT in the Digital Age” (ViDA) initiative aims to modernize VAT rules, with a significant component focused on the Platform Economy. This briefing document analyzes the “Platform Economy” pillar, which introduces new VAT obligations for digital platforms facilitating short-term accommodation and passenger transport by road. Starting July 1, 2028 (with a possible delay to January 1, 2030), these platforms will be treated as “deemed suppliers” and will be responsible for collecting and remitting VAT on behalf of underlying service providers (hosts, drivers) who are not already handling VAT themselves. This reform aims to close VAT loopholes, level the playing field between traditional businesses and the platform economy, and increase VAT revenue for EU member states. This document outlines the key provisions, implications for businesses and tax authorities, and the implementation timeline.
1. Background and Objectives:
- The ViDA initiative comprises three pillars: digital reporting/e-invoicing, the platform economy, and single VAT registration. This briefing focuses on the Platform Economy pillar.
- The primary objective is to address VAT under-collection in the platform economy, particularly in short-term accommodation and passenger transport sectors. The European Commission views this as correcting an “unjustified distortion of competition”.
- The reforms aim to ensure that VAT is collected on services provided via digital platforms, even when the underlying providers are small-scale operators or individuals who were not previously charging VAT.
- The Commission projected that across all ViDA measures, about €18 billion in additional VAT could be collected annually.
2. Key Provisions: Deemed Supplier Rule
- Deemed Supplier Status: Digital platforms facilitating short-term accommodation and passenger transport are considered to buy the service from the provider and then sell it to the consumer. This makes the platform responsible for VAT collection and remittance. The document clarifies: “In practice, this means the platform is considered to buy the service from the provider and sell it to the consumer, making the platform responsible for charging and remitting VAT on those services.”
- Scope of Services: The rule applies to “short-term accommodation rentals” (uninterrupted rentals of a maximum of 30 nights to the same person) and “passenger transport by road” within the EU.
- Exemption for VAT-Registered Providers: The platform is not deemed the supplier if the underlying service provider is VAT-registered, provides their VAT number, and declares they will handle the VAT. As stated in the document: “If the underlying provider is VAT-registered and confirms they will charge VAT, the platform is not deemed the supplier for that transaction.”
- Member State Options:SME Exclusion: Member States can choose to exclude supplies made by small enterprises under their domestic SME VAT exemption regime from the deemed supplier rule.
- Definition of Short-Term Rental: Member States can introduce specific criteria or conditions for what counts as “short-term” accommodation in their jurisdiction.
3. VAT Treatment Under Deemed Supplier Model:
- Supplier’s Supply to Platform: The underlying supplier’s supply to the platform is treated as a VAT-exempt supply without the right to deduct VAT on inputs.
- Platform’s Supply to Customer: The platform’s supply to the final customer is a normal taxable supply, with VAT added at the applicable rate of the Member State where the service is supplied.
- New Place-of-Supply Rule: Any fee or commission that a platform charges to an individual consumer for facilitating a sale will be taxed in the location of the underlying transaction.
4. Record-Keeping Requirements:
- Platforms must keep detailed records of transactions even if they are not deemed the supplier (because the provider is handling VAT).
- These records must be retained for 10 years and provided electronically to any EU Member State upon request.
- The document stresses that authorities want platforms to act as a “data hub” even if they aren’t paying VAT themselves.
5. Implications for Stakeholders:
- Digital Platforms: Face significant new compliance obligations, including updating systems, determining when the deemed supplier rule applies, applying the correct VAT rates, and remitting VAT. The One-Stop Shop (OSS) is designed to ease multi-country compliance. Platforms become “pivotal tax collection agents and data providers.”
- Service Providers (Hosts, Drivers): Individuals previously not charging VAT will now have VAT added to their services, potentially affecting their income. They are spared the administrative burden of VAT registration and returns if the platform handles it. VAT-registered businesses must share their VAT ID with the platform.
- E-Commerce Platforms: While these platforms were addressed in earlier VAT reforms in 2021, ViDA extends some obligations.
- Tax Authorities: Expect increased revenue and simplified enforcement by focusing on a smaller number of large platforms. There’s an initial complexity of implementation, but the goal is long-term uniformity and a fairer competitive environment.
6. Timeline and Implementation:
- March 11, 2025: Formal adoption of the VAT in the Digital Age laws.
- June 30, 2028: Member States must transpose the Platform Economy measures into national law.
- July 1, 2028: Earliest date for Member States to begin applying the new rules.
- January 1, 2030: Latest date by which all EU countries must have the platform VAT model in effect.
- July 1, 2033: European Commission to evaluate the operation of the new platform rules.
7. Current Status (Early 2026):
- No EU Member State has fully implemented the “deemed supplier” VAT collection yet.
- Businesses and platforms are beginning to plan for compliance.
- A draft Explanatory Notes document is expected by Q1 2026 to guide Member States and businesses on applying the new rules uniformly.
8. Conclusion:
The ViDA Platform Economy pillar is a significant reform designed to integrate digital platforms into the EU VAT system. It aims to close loopholes, ensure fair competition, and improve tax compliance. Platforms will face new obligations, but the reforms also offer clearer rules and simplified cross-border compliance. Member States anticipate higher revenues and reduced fraud. The implementation timeline provides a runway for preparation, and ongoing engagement between tax authorities and industry is crucial for a smooth rollout. “The ViDA platform economy measures are thus a pivotal step in bringing EU VAT fully into the digital age.”
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INDEPTH ANALYSIS
Platform Economy Reforms under EU’s “VAT in the Digital Age” (ViDA)
The European Union’s VAT in the Digital Age (ViDA) initiative is a package of reforms to modernize VAT rules. It consists of three pillars: (1) digital reporting/e-invoicing, (2) platform economy, and (3) single VAT registration. This report focuses on the second pillar – the Platform Economy – which introduces new VAT obligations for digital platforms. Under Council Directive (EU) 2025/516 (adopted 11 March 2025), the EU will require online platforms to collect and remit VAT on certain services (notably short-term accommodation and passenger transport) in cases where the underlying providers were previously not charging VAT. The following sections summarize the key provisions of this reform and explore its implications for businesses, tax authorities, and digital platforms across all sectors (e-commerce marketplaces, ride-sharing apps, home-sharing/accommodation platforms, etc.) within the EU. [en.wikipedia.org] [consilium.europa.eu]
Key Provisions of the Platform Economy Pillar
Starting 1 July 2028 (with mandatory adoption by 1 January 2030), digital platforms facilitating short-term accommodation rentals or passenger transport by road will be treated as “deemed suppliers” for VAT purposes. In practice, this means the platform is considered to buy the service from the provider and sell it to the consumer, making the platform responsible for charging and remitting VAT on those services. This deemed supplier rule applies only if the underlying service provider is not handling VAT themselves. In other words: [en.wikipedia.org], [vatcalc.com] [consilium.europa.eu]
- If an apartment host or driver does not provide a VAT number and does not personally charge VAT (for example, an individual renting out a flat or a small operator under a VAT exemption threshold), then the platform must collect the VAT from the customer and pay it to the tax authorities. [grantthornton.nl], [consilium.europa.eu]
- If the underlying provider is VAT-registered and confirms they will charge VAT, the platform is not deemed the supplier for that transaction. In such cases the original provider remains responsible for VAT, and they give their VAT identification number to the platform and declare that they will handle the VAT on the sale. [eur-lex.europa.eu], [globaltaxnews.ey.com] [globaltaxnews.ey.com]
The new rules target the two largest “platform economy” service sectors that have seen VAT under-collection: short-term accommodation rentals and passenger transport by road. Short-term accommodation is defined in the directive as an uninterrupted rental to the same person for a maximum of 30 nights. This aligns such rentals with the hospitality (hotel) sector, ensuring they are taxed similarly to hotels rather than benefiting from VAT exemptions that often apply to long-term residential rentals. “Passenger transport by road” covers ride-hailing or similar transport services within the EU (e.g. car rides via apps). Other types of platforms, such as e-commerce marketplaces for goods, are not the primary focus of this pillar (they were addressed by earlier reforms in 2021), and services like food delivery or freelance gigs are not explicitly included in the new deemed supplier rule. The Council notably decided not to extend the deemed supplier model to all goods or other services beyond these sectors in the final law, choosing to focus on accommodation and transport where VAT avoidance was deemed most acute. [eur-lex.europa.eu], [consilium.europa.eu] [eur-lex.europa.eu], [grantthornton.nl] [eur-lex.europa.eu] [consilium.europa.eu] [en.wikipedia.org], [eur-lex.europa.eu]
To account for national specifics, the rules include some flexibility for EU Member States:
- SME Exclusion Option: A Member State may choose to exclude supplies made by small enterprises under its domestic SME VAT exemption regime from the deemed supplier rule. For example, if a country believes very small-scale hosts or drivers pose minimal distortion in its market, it can decide that the platform need not charge VAT on those particular supplies. This was a compromise to address concerns (notably raised by Estonia) about burdening micro-entrepreneurs. If exercised, the Member State must set conditions (e.g. confirming the provider’s status as an exempt small business) and inform the EU VAT Committee of this choice. Importantly, even if a Member State exempts SME-based supplies, platforms still carry the general obligation to comply with the new rules for all other cases in that country. [eur-lex.europa.eu], [grantthornton.nl] [en.wikipedia.org], [consilium.europa.eu] [eur-lex.europa.eu], [eur-lex.europa.eu]
- Definition of Short-Term Rental: While the baseline definition is rental up to 30 days, Member States can introduce specific criteria or conditions for what counts as “short-term” accommodation in their jurisdiction. For instance, a country could impose additional rules (perhaps about rental frequency or licensing) as long as they inform the European Commission, which will publish a list of each state’s criteria by end of 2028. [eur-lex.europa.eu], [eur-lex.europa.eu] [eur-lex.europa.eu]
- Transition Period: The directive acknowledges that a transition period is needed for these changes. Although the formal EU implementation date is mid-2028, states may delay applying the deemed supplier rule until 1 January 2030 at the latest. This gives a short grace period if a country needs extra time to adapt its laws or if it initially believed there was no competitive distortion domestically. All Member States must adopt the necessary national laws by 30 June 2028, even if they opt to enforce them later. [en.wikipedia.org], [vatcalc.com] [eur-lex.europa.eu], [eur-lex.europa.eu] [eur-lex.europa.eu], [vatcalc.com]
Under the deemed supplier model set out in the Directive, the VAT is handled as follows for a covered transaction (e.g. a short stay via an online platform):
- The underlying supplier’s supply to the platform is deemed an VAT-exempt supply. This means when, say, a host “sells” their rental service to the platform (fictionally), that supply is exempt from VAT so that the host doesn’t have to charge VAT to the platform. However, this exemption comes without the right to deduct VAT on inputs for that underlying supplier. In practical terms, an individual host or driver usually wouldn’t be VAT-registered or incurring input VAT in a business capacity anyway. But if they are a small business with some VAT-bearing costs, choosing not to handle VAT and letting the platform do it means they forego claiming VAT on those costs. This provides an incentive for any larger providers to register for VAT themselves (so they can deduct input VAT) rather than relying on the platform’s deemed supplier treatment. [globaltaxnews.ey.com], [bdo.global] [bdo.global]
- The platform’s supply to the final customer is treated as a normal taxable supply of the service. The platform must add VAT at the applicable rate of the Member State where the service is deemed supplied. For example, if a ride is taken in Country X with a 20% VAT rate on transport, the platform will charge the rider 20% VAT on the fare and later remit that to Country X’s tax authority. The platform’s right to deduct input VAT on its own expenses (e.g. its service fees, marketing costs) is preserved – the law explicitly states the deemed supply mechanism does not affect the platform’s deduction rights. In other words, making the platform the collector of VAT doesn’t penalize it in terms of VAT recovery. [globaltaxnews.ey.com]
- Exclusion of Special Schemes: Transactions covered by the Tour Operators’ Margin Scheme (TOMS) are explicitly kept outside the platform deeming rules. This avoids overlap in cases where a platform might otherwise fall under travel agent rules. Similarly, genuine travel agents and tour operators using TOMS won’t suddenly be treated as “platforms” under the new rule. [globaltaxnews.ey.com] [eur-lex.europa.eu], [eur-lex.europa.eu]
ViDA also introduces a clarifying rule for the VAT treatment of the platform’s facilitation service itself. As of 1 July 2028, any fee or commission that a platform charges to an individual consumer (for facilitating a sale) will be taxed in the location of the underlying transaction. Previously, some countries treated platform fees to consumers as electronic services taxed where the customer resides, while others taxed them where the underlying service took place, leading to inconsistency. The new Article 46a of the VAT Directive harmonizes this: if a platform charges a service fee to a non-business user in the course of arranging an accommodation or ride, that fee is VAT-taxed in the same country as the accommodation or ride itself. For example, a booking platform’s service charge on a French apartment rental would be subject to French VAT, ensuring coherence (and preventing platforms from potentially locating elsewhere to avoid higher VAT on their fees). This change helps eliminate confusion and ensures platforms’ commissions don’t slip through tax jurisdiction gaps. [globaltaxnews.ey.com], [grantthornton.nl] [eur-lex.europa.eu]
Whether or not a platform is deemed the supplier, the directive imposes record-keeping obligations on platform operators. If the platform is facilitating short-term accommodation or road transport but is not deemed the supplier (because the provider gave a VAT number and charges VAT themselves), then the platform must keep detailed records of those transactions. The data must be sufficient for tax authorities to verify that VAT was correctly accounted for by the provider. Platforms have to retain these records for 10 years and provide them electronically to any EU Member State that requests them. Member States can even require regular provision of this data until an automated sharing system is in place. In essence, even in cases where the platform isn’t paying the VAT, the authorities want the platform to act as a data hub to help audit the underlying suppliers. This aligns with broader transparency efforts (complementing measures like the DAC7 directive, which also obliges platforms to report income of sellers to tax authorities). [eur-lex.europa.eu]
It’s important to note that the platform economy pillar for ViDA primarily addresses services (transport and accommodation). The e-commerce platforms dealing in goods were addressed by separate VAT reforms effective in 2021. Under those existing rules (Directive (EU) 2017/2455 and 2019/1995), online marketplaces are already deemed suppliers for certain sales of goods – for example, imports of low-value goods and sales by non-EU vendors through EU platforms. The new Directive 2025/516 does make some adjustments to those rules (Article 14a of the VAT Directive is revised to further extend the deemed supplier treatment to intra-EU sales by non-EU sellers), but the principle remains: marketplaces like Amazon, eBay, AliExpress, etc., must handle VAT on many B2C goods transactions. The Council ultimately chose not to broaden the deemed supplier model to all goods transactions in this ViDA package. So for goods e-commerce, platforms continue following the post-2021 framework. The Platform Economy pillar of ViDA can be seen as equivalent treatment being extended into the “sharing economy” services realm, which until now often escaped VAT. [eur-lex.europa.eu] [consilium.europa.eu]
Implications for Businesses and Digital Platforms
Platforms facilitating accommodation sharing or ride-hailing will face significant new compliance obligations. They must update their systems to: (1) determine when a transaction triggers the deemed supplier rule (i.e. checking if the provider has given a valid VAT number and declaration), (2) apply the correct VAT rate of the Member State of consumption on the service price, (3) collect that VAT from the consumer at checkout, and (4) remit the VAT to the appropriate tax authority via periodic returns. This is a major shift for platforms that previously served largely as intermediaries and left tax matters to individual hosts/drivers. Platforms will likely need to register for VAT under the new One-Stop Shop (OSS) simplification: a key benefit of the ViDA reforms is that a deemed-supplier platform can use the OSS to report VAT for all EU countries in one place. For instance, an accommodation platform could choose one EU country to register and then declare VAT for rentals in France, Spain, Italy, etc., all through a single OSS return, rather than registering in every country. This reduces the administrative burden of multi-country compliance, albeit the platform still must calculate and apply each country’s VAT rates. [consilium.europa.eu] [vatcalc.com], [consilium.europa.eu]
The individuals and businesses who actually provide accommodation or transport via platforms will experience changes in how VAT affects them:
- Previously unregistered individuals: Many casual hosts or ride-share drivers are private individuals or very small-scale operators who have until now done business without charging VAT (legally, because they fell under exemptions or thresholds, or sometimes simply out of ignorance of obligations). With the platform stepping in to charge VAT on their transactions, their services will effectively become VAT-taxed to the consumer. This could reduce the net earnings for those providers or make their service pricier, potentially affecting their income. On the other hand, these individuals will not need to register or file VAT returns themselves, which spares them administrative hassle. The platform takes over that compliance burden. In essence, the reform formalizes and taxes the informal supply, bringing it into the tax system with minimal action required by the individual provider. This might slightly reduce the competitive edge that non-taxed peer-to-peer services had over traditional taxed businesses, fulfilling the “level playing field” goal. For example, a part-time host on a booking site might find nightly rates a bit higher for guests due to VAT, narrowing the gap with hotel pricing, but the host doesn’t have to do any tax paperwork personally. [consilium.europa.eu]
- Small businesses under national VAT exemption: Many EU countries have a VAT registration threshold or a simplified scheme for small businesses (the SME special scheme). Such providers (e.g. a small B&B owner under a threshold) could optionally remain outside VAT if their country decides to exempt SME supplies from the platform deeming rule. If exempt, then even after 2028 the platform wouldn’t charge VAT on their rentals/rides. This means some small providers might continue business as before (no VAT in price), at least in certain countries. However, if a country does not exercise this exemption, even tiny businesses will have VAT added via the platform. Those who want to avoid having the platform add VAT might consider opting into VAT voluntarily or providing their VAT number if they have one. For those already in business and VAT-registered (like a professional property manager or a taxi firm using a platform to get customers), the change simply means they must share their VAT ID and charge VAT themselves to keep the platform out of it. If they do so, nothing really changes in their economic VAT situation – except they’ll need to ensure the platform knows they are handling the VAT. [eur-lex.europa.eu], [grantthornton.nl] [eur-lex.europa.eu]
- Ability to deduct VAT: A provider who remains outside VAT and lets the platform handle it will not charge VAT, but also cannot deduct VAT on expenses (since from their perspective their supply to the platform was “exempt without credit”). For many casual providers, this is a non-issue (they might not incur significant VAT on costs). Larger providers, however, will likely prefer to be VAT-registered themselves. The rules effectively encourage any serious business operating via platforms to register for VAT and thus declare their own sales, because otherwise the platform’s involvement denies them input VAT recovery. For example, a property rental agency renting many apartments via platforms would likely provide its VAT number to avoid the platform deeming. That way, it charges VAT to the guests directly and still can reclaim VAT on its costs (cleaning services, utilities, etc.). [bdo.global]
In the goods e-commerce sector, large marketplaces have already adapted to VAT deeming rules since 2021 (for example, collecting VAT on imports under €150 and on certain domestic supplies by foreign sellers). The ViDA changes for platforms do extend some obligations (from 2027, marketplaces will also be deemed suppliers for any sale of goods within the EU by an overseas seller to a consumer, closing a gap in the prior rules). Additionally, the OSS (One-Stop Shop) system is being expanded by 2028 to allow platforms to report even more types of supplies, including certain domestic sales. Thus, online retailers and marketplaces should prepare for a more comprehensive use of OSS and ensure they can track which sales fall under the new expanded deemed-supplier scope for goods. However, fundamentally, the concept of platform VAT liability is not new to e-commerce – what’s new is the extension of the concept to services like rides and accommodation. [eur-lex.europa.eu] [vatcalc.com]
EU tax authorities stand to gain from the Platform Economy reforms in multiple ways:
- Increased Revenue and Reduced VAT Gap: The primary driver for these rules was the substantial VAT revenue lost in the platform-based economy. Many small providers did not charge VAT, creating what the European Commission viewed as an “unjustified distortion of competition” and contributing to the overall VAT gap (the EU’s VAT gap was estimated at €93–99 billion in 2020). By shifting the responsibility to a limited number of large platforms, authorities expect to capture VAT that was previously going uncollected. For example, every apartment rented via a platform in Paris by an individual owner will now produce 10% VAT for France (or 20% if it’s a furnished rental considered a hospitality service) which the treasury was likely not receiving before. This should bolster public revenues. The Commission projected that across all ViDA measures, about €18 billion in additional VAT could be collected annually, with a significant portion directly from anti-fraud and platform provisions. [eur-lex.europa.eu], [en.wikipedia.org] [consilium.europa.eu] [en.wikipedia.org], [en.wikipedia.org]
- Simplified Enforcement: Instead of trying to monitor and audit millions of small, often part-time service providers, tax offices can focus on a handful of major platform companies. It is far more efficient to enforce compliance among large, sophisticated entities that have formal accounts and IT systems, than among the fragmented long tail of individuals. Platforms can be expected (and legally required) to cooperate, providing data and ensuring VAT is charged by default. This outsourcing of VAT compliance to platforms effectively turns those companies into tax intermediaries, which eases the administrative burden on authorities. Tax authorities will also benefit from the data sharing provisions – platforms must keep transaction details and provide them on request, enabling audits and cross-checks. In combination with the administrative cooperation enhancements (Council Regulation (EU) 2025/517, adopted alongside the directive, will facilitate information exchange among tax administrations), authorities will be better equipped to detect evasion. For instance, if a provider claims to be charging VAT (to avoid the platform doing so) but isn’t remitting it, the platform’s records and cross-border data exchange could help catch that. [consilium.europa.eu] [eur-lex.europa.eu]
- Short-Term Complexity, Long-Term Uniformity: Tax authorities do face an implementation challenge: updating national VAT laws by 2028, educating domestic businesses, and adapting their IT systems to new reporting from OSS and platforms. They also must clarify how the optional provisions (like the SME exclusion) will be applied nationally. Some authorities might initially see increased rulings requests or questions – e.g. “Is my business considered short-term accommodation under the new rules or not?” Hence, the Commission is preparing Explanatory Notes (guidance) in consultation with Member States (a draft is expected by early 2026) to ensure consistent interpretation across the EU. Once in place, however, the rules aim for harmonization. By explicitly defining the VAT treatment for these platform services EU-wide, it reduces divergent national approaches. This uniform treatment helps tax authorities by closing loopholes (no arbitrage between countries’ VAT rules) and by making compliance more straightforward for companies that operate in multiple EU states. [vatcalc.com], [vatcalc.com]
- Effect on Traditional Sectors: Finally, tax authorities anticipate a fairer competitive environment between the platform-facilitated sector and traditional VAT-compliant businesses. Taxi firms and hotels, for example, have long argued that they must charge VAT while their peer-to-peer competitors effectively enjoyed a tax break. With platforms charging VAT on rides and short stays, authorities neutralize that complaint. This may indirectly help sustain the tax base of traditional sectors as well (preventing an exodus of consumers purely due to VAT-induced price differences). [eur-lex.europa.eu], [consilium.europa.eu]
Timeline of Development and Implementation
- 2020 – 2022: Initiative and Proposal
The concept of updating VAT for the digital/platform economy was introduced as part of the European Commission’s Tax Action Plan 2020. After study and consultations, on 8 December 2022 the Commission unveiled the ViDA legislative proposals, which included proposed rules to “update VAT rules for the platform economy”. The proposal targeted a July 2027 implementation for platform deeming, but this was subject to change during negotiations. [en.wikipedia.org], [en.wikipedia.org] [vatcalc.com] - Late 2022 – 2024: Negotiations and Political Agreement
Because EU VAT legislation requires unanimous agreement of all Member States, extensive negotiations took place throughout 2023 and 2024. A key point of contention was the mandatory VAT role for platforms in accommodation and transport. Estonia in particular raised objections, arguing against an obligatory EU-wide approach (in part due to concerns for its home-grown platform company Bolt). This led to protracted discussions. Compromises were made: the implementation date was pushed from 2027 to 1 July 2028, and Member States were allowed the option to delay until 2030 and to exempt small suppliers. On 5 November 2024, EU finance ministers (ECOFIN Council) reached unanimous political agreement on the final ViDA package, including the Platform Economy pillar with these adjustments. The agreement was hailed as a major step in modernizing VAT and balancing Member States’ concerns. [en.wikipedia.org] [en.wikipedia.org], [en.wikipedia.org] [bdo.global], [bdo.global] [consilium.europa.eu], [consilium.europa.eu] - March 2025: Formal Adoption
Following European Parliament consultation, the Council formally adopted the VAT in the Digital Age laws on 11 March 2025. The package comprises Directive (EU) 2025/516 (amending the main VAT Directive 2006/112/EC) and accompanying regulations for administrative cooperation and implementation. The laws were published in the EU Official Journal on 25 March 2025 and entered into force on 12 April 2025. From this date, Member States had the green light to begin transposing the rules into national law. [en.wikipedia.org] - Transposition and Member State Implementation (2025–2028):
Under the directive’s timetable, Member States must transpose the Platform Economy measures by 30 June 2028 and apply them from 1 July 2028. However, a special clause allows that the core deemed supplier rule (Article 28a of the VAT Directive) need not be applied until 1 January 2030 at the latest. This gives flexibility if a country needs a bit more time or wants to phase in the change. It’s expected that most Member States will target the 2028 date or soon after, to boost revenues and align with EU partners, but they have the legal right to hold off until 2030 if justified. [eur-lex.europa.eu] [eur-lex.europa.eu], [vatcalc.com] - As of early 2026, Member States are in preparation mode. They are likely drafting legislation and considering how to implement options. For instance, each country must decide whether to use the SME exclusion option (and define what it considers a small enterprise under that rule). Tax authorities are also working through practical aspects: updating OSS systems, gearing up VAT registration processes for possibly many platform companies, and collaborating on the upcoming Commission Explanatory Notes. In September 2025, a Fiscalis workshop with all Member States and stakeholders was held to discuss implementation challenges for the platform rules. These discussions highlighted issues like how to handle complex supply chains, how exactly to determine a provider’s status, and how to avoid double taxation in tricky scenarios. Feedback from such meetings will feed into detailed guidance. A draft Explanatory Notes document is expected by Q1 2026 to guide Member States and businesses on applying the new rules uniformly. [eur-lex.europa.eu], [grantthornton.nl] [vatcalc.com], [vatcalc.com]
While no country can enforce the deemed supplier rule before 1 July 2028 (the directive actually forbids applying it earlier than that date), some may proactively adjust related laws beforehand. For example, Member States could align their definition of “short-term accommodation” with the directive’s criteria or start requiring platforms to report information even prior to 2028 (some countries already have domestic reporting rules for platforms, and the EU’s separate DAC7 reporting came into effect in 2023). A few Member States with existing digital economy taxes might streamline those in anticipation of ViDA. By the end of 2025, none had fully implemented the new VAT collection obligations (since the EU law was brand new), but governments in countries with large platform activity (like France, Germany, Spain, etc.) signaled support for timely implementation. Notably, some nations that already charge VAT on short rentals in certain cases will integrate those practices with the new deeming model. [eur-lex.europa.eu], [vatcalc.com]
On 1 July 2028, the EU-wide system officially kicks in. From that date, any Member State that has transposed the rules will see platforms begin to charge VAT on the affected transactions. It’s expected that a majority of states will enforce it by this time or shortly thereafter. Member States that choose to delay (perhaps those with very few such platform transactions or political hesitancy) have until 1 January 2030 to apply the rules. By 2030, all EU countries must have the platform VAT model in effect. The staggered uptake means there could be an 18-month period where in some countries the old regime still holds. Platforms operating EU-wide will need to be cognizant of which countries are “live” with the new system. (For example, if Country A delays to 2030 but Country B starts in 2028, the platform must charge VAT for rentals in Country B but not for identical rentals in Country A until that later date.) This complexity will disappear by 2030 when the rules unify across all states. [vatcalc.com]
The directive mandates that the European Commission evaluate the operation of the new platform rules by 1 July 2033. This review will examine the impact on the internal market and VAT collection effectiveness, and consider any further adjustments. By that time, the EU will have several years of data on VAT revenues from platforms and any lingering issues (for instance, whether the SME exclusion in some countries creates distortion, or if any platforms or providers found workarounds). The Commission could then propose refinements or expansions if needed. Additionally, the administrative cooperation measures (Regulation 2025/517) will be in effect from 2027, aiding enforcement as soon as platforms start collecting VAT. [eur-lex.europa.eu] [en.wikipedia.org]
At present, no EU Member State has fully implemented the “deemed supplier” VAT collection yet – that step is forthcoming as described. However, awareness is growing among businesses. Platforms are beginning to plan for compliance (some have even started voluntarily assessing VAT on certain fees to test systems). Tax advisors are actively guiding clients in the hospitality and transport sectors about what to expect. The transition is being closely watched: it represents one of the most significant shifts in VAT administration in recent years, effectively bringing parts of the informal digital economy into the taxed formal economy across the whole EU. By late 2025, the legal framework is set; the focus has moved to practical implementation on the ground. [consilium.europa.eu]
The Platform Economy pillar of VAT in the Digital Age is a landmark reform that integrates modern digital platforms into the VAT system of the European Union. By making platforms in sectors like accommodation and ride-sharing responsible for VAT, the EU aims to close loopholes, ensure fair competition, and harness technology for better tax compliance. All types of platforms – from e-commerce marketplaces to gig-service apps – are coming under greater tax scrutiny, and the trend is clearly toward platforms acting as tax collectors on behalf of users. While the core of Directive 2025/516 specifically targets short stays and passenger transport, its ripple effects and the supporting measures (like OSS expansion and data sharing) affect the broader digital marketplace. [consilium.europa.eu]
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