The European Association of Co-operative Banks (EACB) welcomes the opportunity to participate in the survey for payment industry actors on the exchange of VAT-relevant payment data.
In October 2019, EACB together with European Banking Federation, European Savings and Retail Banking Group and European Payment Institutions Federation (EPIF) published a Joint Position commenting on the proposal for a Council Directive amending Directive 2006/112/EC as regards introducing certain requirements for payment service providers. Whilst the European Credit Sector Associations (ECSAs) and EPIF strongly support the fight against VAT and other tax fraud, they stressed that the proposals did not constitute relevant measures to fight VAT fraud.
The EACB response to the current survey suggests that implementing the amended Directive will be complex and challenging. Among others, different banks store the relevant data differently, use different IT solutions, use different types of identifies for certain transactions, such identifiers do not always contain the relevant data about the beneficiary. In many instances, the EACB indicated that guidelines will be necessary to clarify PSPs' obligations under the amended Directive or that the expert group will have to determine a workable solution.