Financial industry against VAT fraud: joint position paper

Brussels, 30 October 2019

Financial industry against VAT fraud: joint position paper

The European Banking Federation, European Savings and Retail Banking Group, European Association of Co-operative Banks, European Payment Institutions Federation (and their respective members) strongly support the fight against VAT and other tax fraud but are deeply concerned that 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, we would welcome your 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

1) Is practical and workable for the industry to deliver and
2) Meets the needs of Member States in terms of effectively combatting VAT fraud.

In current form, our 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.

We 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, we believe these have been misunderstood and in some areas simply ignored.