Joint Industry Position on the proposal for a Council Directive as regards introducing certain requirements in order to combat VAT Fraud

30 October 2019

The European Banking Federation, European Savings and Retail Banking Group, European Association of Co-operative Banks, European Payment Institutions Federation strongly support the fight against VAT and other tax fraud but have some concerns regarding the current proposals.

Based on them in current form the proposals:

• are disproportionate in terms of scope, volume of data required and cost,
• create significant risk,
• produce uncertainty in terms of reporting obligations,
• will not practically achieve stated objectives.

With the current proposal seeking to be approved at November’s ECOFIN, they would welcome support in terms of prompting a full review of the proposals with the active involvement of the Payments Industry. The objective would be to ensure that the proposal is not approved until it has been amended into a form that

• is practical and workable for the industry to deliver and
• meets the needs of Member States in terms of effectively combatting VAT fraud.

In current form, their firm view is that the proposal achieves neither.

It is absolutely clear that Member States must have effective and efficient tools to combat VAT and tax fraud and the Payments Industry is fully prepared to work closely to ensure that this can be delivered.

They are however troubled that whilst concerns have been raised with the Commission, including recommendations on how to improve the proposals to achieve its stated objectives and to align it with the highly complex, multi-party and rapidly evolving nature of the payments industry, they believe these have been misunderstood and in some areas simply ignored.

Full position on EBF

© EBF