TEI Responds to the European Commission's Public Consultation Regarding the Definitive VAT System for Business-to-Business Intra-EU Transactions on Goods.

• Position: Tax Executives Institute, value added tax

On March 19, 2017, TEI filed a response to the European Commission's Public Consultation on the Definitive VAT System for Business-to-Business Intra-EU Transactions on Goods

We write in response to the European Commissions (Commission) Public Consultation on the Definitive VAT System for Business-to-Business (B2B) Intra-EU Transactions on Goods (Consultation). Tax Executives Institute (TEI) appreciates the Commissions efforts to revise and simplify the rules concerning cross-border supplies and level the playing field for companies in the European Union (EU) market. We welcome the opportunity to speak with you regarding the comments and recommendations contained in this letter.

About Tax Executives Institute

TEI is the preeminent association of in-house tax professionals worldwide and was founded in 1944 to serve the professional needs of business tax professionals. TEI espouses organizational values and goals that include integrity, effectiveness, efficiency, and dedication to improving the tax system for the benefit of taxpayers and tax administrators.

TEI's approximately 7,000 professionals manage the tax affairs of over 2,800 companies across all industry sectors around the world. TEI's members are accountants, lawyers, and other corporate and business employees responsible for the tax affairs of their employers in an executive, administrative, or managerial capacity, and continually monitor consumption tax developments around the world. Many of these members' companies have a business presence and/or sell into all 28 EU Member States.

TEI believes it is critical to maintain a dialogue between businesses and revenue authorities when developing VAT rules to ensure such rules are workable and not overly burdensome on business or tax authorities. Moreover, TEI supports the Commission's efforts to protect the neutrality, simplicity, and workability of the VAT system.

Comments

The following comments elaborate on TEI's responses to the questions posed by the Commission.

Question 15: The current system, which treats domestic and intra-EU supplies of goods differently for VAT purposes, discourages some businesses from supplying goods cross-border. In particular, the current system discourages small and medium-sized enterprises (SMEs) from cross-border sales because the documentation and compliance burdens (transport documentation, EC sales listings) are higher for intra-EU cross-border supplies of goods than domestic supplies. In addition, the...