While the EACB acknowledges that the current EU VAT system needs to be improved to keep pace with the latest digital and technological developments, we however note with concern that the “VAT in the digital age” initiative is likely to result in additional compliance costs and even more complex and burdensome rules for businesses. It is not justified in our view that the initiative lacks the intention to make a more effective and efficient use of information that tax authorities of EU Member States already possess to fight fraud, for example on basis of sales listing figures.
As regards the VAT Digital Reporting Requirements, we believe that there is not a sufficient assessment on how information that tax authorities already possess to fight fraud could be recycled for the purpose of the current initiative. Apart from that, 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 for which purpose the data is collected including how the data can be examined by tax authorities. Finally, the storage period of the data has to be clearly defined.