EACB comments regard the proposed introduction of Digital Reporting Requirements (DRR) to modernise VAT reporting obligations.
We are pleased that the need for a carve out of VAT exempt supplies from the DRR for which the EACB has advocated during the 2022 public consultation stage has been recognised in the current proposal. However, we further stressed the ways in which the proposal could be optimised for the financial sector by amending Article 272(1)(c).
- Furthermore, there is a number of data-related issues that the EACB encourages the European Commission to consider in its future deliberations on the proposal for a Directive as regards VAT rules for the digital age:
- The proposed time limit for the issuance of invoices of two working days after the chargeable event takes place is too short.
- Besides the recipient’s verification obligations of an electronic invoice, clear instructions should be provided for cases when a mistake has been identified.
- Clarification needs to be inserted as regards the situations when invoices are drawn up by the recipient of goods or services instead of a taxable person.
- The reporting obligations have to be reduced to data that is needed to fight tax fraud.
- Data security has to be ensured and the provisions must clearly state the purpose of data collection by Member States.