Summary
- The Commission presented updated draft explanatory notes on platform economy, Single VAT Registration (SVR) and Digital Reporting Requirements (DRR) under ViDA.
- Delegates broadly supported the direction of travel but requested clearer scope definitions, stronger consistency, and practical examples.
- Several technical and transitional issues remain unresolved, with further written feedback and revisions planned before publication.
Source Group of the Future of VAT – Minutes
Article
- Context: Focus on ViDA Implementation
The 51st meeting of the Group on the Future of VAT (GFV) was entirely dedicated to the implementation of the VAT in the Digital Age (ViDA) package, reflecting the Commission’s shift from legislative design to practical application. The discussions centred on draft Explanatory Notes</strong> intended to clarify how the new rules should be applied in practice, without altering the legal text itself.
- Platform Economy: Scope, Terminology and Transitional Challenges
The Commission introduced the first draft Explanatory Notes on the platform economy, emphasising that the document remains a work in progress and will be expanded with diagrams and additional examples.
Key points of discussion included:
- Scope clarification, notably the treatment of farmers covered by the flat-rate scheme.
- The obligation of underlying suppliers to provide a VAT identification number, illustrated through multiple scenarios.
- Alignment of terminology strictly with that used in the VAT Directive.
- The interaction between Article 28a, Article 28, and the Tour Operators’ Margin Scheme (TOMS).
- Transitional situations, such as bookings made before 1 July 2028 but supplied afterwards.
- Treatment of chain transactions, where the majority of delegates supported the Commission’s proposed approach.
Overall, there was broad appreciation for the draft, combined with strong calls for more real-life examples to improve legal certainty for platforms and suppliers.
- Single VAT Registration: Technical Adjustments Ahead of Major Reform
The Commission also presented the first draft Explanatory Notes and OSS guidelines on Single VAT Registration (SVR), focusing on technical changes entering into force from 1 January 2027.
It was stressed that these updates are transitional in nature. A comprehensive rewrite is expected later, once the more substantial ViDA changes apply from 1 July 2028.
Discussions touched on:
- The mutual exclusivity between the SME exemption scheme and the Import One Stop Shop (IOSS).
- New rules on the taxable event for the Union and non-Union OSS schemes, for which further written input was requested.
- The possibility of enhancing OSS portals with national procedural rules, still under consideration.
The Commission explicitly invited further written contributions to support its technical assessment.
- Digital Reporting Requirements: Complexity and Consistency Concerns
The most extensive debate related to the second draft Explanatory Notes on Digital Reporting Requirements (DRR). While acknowledging progress since the first draft, the Commission confirmed that revisions are ongoing and that graphics, tables and drawings are still missing.
Delegates raised a wide range of issues, including:
- The need to clarify that accreditation of service providers is advisory rather than mandatory for Member States.
- Unclear definitions of issuance, reception and transmission of invoices, and inconsistent terminology.
- Diverging views on invoice corrections, payments on account, and the definition of a transaction.
- The treatment of attachments, hybrid invoices, EDIFACT, and extensions for intra-Community transactions.
- Concerns around transitional measures, sanctions, penalties, and reporting of non-required data.
- The reminder that formal controls are not a prerequisite for invoice validity.
Several delegates stressed that more consistent examples and alignment with the EU e-invoicing standard are essential to avoid fragmentation at national level.
- Next Steps and Timeline
Delegates were invited to submit written comments on the draft explanatory notes by 24 March 2026. Looking ahead, the Commission confirmed a series of joint GFV/VEG online meetings:
- 25 June 2026 to discuss updated drafts
- 19 November 2026 to finalise the texts for publication in 2027
- Additional sessions to address broader VAT challenges beyond ViDA and financial services
Other Newsletters
- The European Commission’s Group on the Future of VAT met to discuss the implementation of the VAT in the Digital Age (ViDA) package, which aims to modernize VAT for the digital economy and combat tax fraud.
- Key discussion areas included clarifying rules for the platform economy (e.g., deemed supplier status, transitional periods), guidelines for single VAT registration under the One-Stop Shop (OSS), and refining digital reporting requirements (e.g., e-invoicing details, treatment of attachments, invoice corrections).
- The Commission is collecting written comments and has scheduled further joint meetings with the VAT Expert Group throughout 2026 to finalize explanatory notes for publication in 2027, addressing the various complexities and outstanding issues.
- Platform economy (effective 1 July 2028): Discussions focused on the scope of the deemed‑supplier rules (notably for flat‑rate farmers), VAT number obligations for underlying suppliers, interaction between Articles 28 and 28a and TOMS, and complex scenarios such as chain transactions, incorrect deemed‑supplier qualification, and transitional issues.
- Single VAT Registration & OSS (from 1 January 2027): The first draft explanatory notes addressed key design choices, including the mutual exclusion between the SME exemption (KOR) and IOSS, revised rules on the taxable event, clarification of the concept of fiscal representation, and the role of the “group of 4” within the deemed‑supplier framework.
- Digital Reporting Requirements: The second draft triggered extensive debate on accreditation of service providers, definitions of invoice issuance and transmission, corrections, treatment of advances and hybrid invoices, use of EU standards (including annexes and EDIFACT), and the reporting of sensitive goods.
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
- Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE
Latest Posts in "European Union"
- Ine Lejeune/Herman van Kesteren analyse EGC T-221/25 (TUI): ”Implicit VAT Legislation, Legal Certainty and the Right to Property”
- Advocate General Advises EU Court Referral on VAT for Pension Contributions
- EU Strengthens Cross-Border Fight Against VAT Fraud
- CJEU Stellantis Judgment Clarifies VAT Treatment of Transfer Pricing Adjustments
- Comments on ECJ C-603/24 (Stellantis Portugal) – Transfer pricing and VAT: Court confirms in Stellantis that not every true-up constitutes a service
