EUU, Alm.del - 2021-22 - Bilag 485: Regeringens høringssvar til Kommissionens offentlige høring vedr. momsdirektivet

Europaudvalget 2021-22
EUU Alm.del Bilag 485
Offentligt

Response to the European Commission’s consultation document

VAT in the Digital Age

The proposal for a revision of the VAT Directive should address the fol-

lowing:

•

Member States no longer having to ask for an explicit derogation

for introducing mandatory e-invoicing for B2B transactions

Define common minimum standards and requirements for digital

reporting and e-invoicing across EU member states to avoid frag-

mentation, e.g., Peppol BIS (European Standard) for e-invoicing

DANISH BUSIN ESS AUTHO RIT Y

Dahlerups Pakhus

Langelinie Allé 17

DK-2100 København Ø

Denmark

Tel

Fax

+45 35 29 10 00

+45

35 29 10 01

The digital transition to a databased economy with the use of digital tech-

nologies and automated services is developing rapidly and is an important

driving force for future growth and innovation. As one of the most digit-

ized countries in the world, Danish businesses hold a strong position for

adapting to the digital transition. However, many Danish businesses spend

a lot of time on administration due to manual bookkeeping and reporting

to the authorities. It costs Danish businesses (approx. 418.000 businesses)

approximately 49 billion DKK (approx. 6,6 billion EUR) annually in man-

ual processes on bookkeeping and complying with national reporting re-

quirements. In addition, many businesses have difficulties complying with

the rules, as errors are found in 48 percent of the VAT returns and 62

percent of the reported annual accounts.

The adoption of e-invoicing represents huge potentials for both businesses

and public authorities. From a business perspective it can simplify the

bookkeeping process, minimize burdens and lead to higher accuracy and

timely reporting. From a public sector perspective e-invoicing and digital

bookkeeping can create a basis for more efficient targeted audits and con-

trol of businesses’ reporting.

VAT is one of the most important sources of tax revenue for governments,

and lost tax revenues approach approximately around 164 billion EUR

across the EU in 2020. A move towards e-invoicing and digital VAT re-

porting has become highly introduced as a means of reducing the lost

VAT revenues and are currently being adopted across the EU member

states. Several EU countries are digitizing their VAT reporting systems

and promoting e-invoicing to increase VAT compliance and boost their

VAT revenues.

Several EU countries are looking towards implementing mandatory e-in-

voicing for business to business (B2B) transactions. This has been encour-

aged by the successful implementation of mandatory e-invoicing in B2G

transactions across the EU, improved and more efficient business admin-

istration as well as evidence of significant decreases in VAT gaps. Italy

was the first EU Member State to introduce mandatory electronic invoic-

ing B2B, by adapting an ‘invoice clearance’ model effective from 2019.

Mandatory use of B2B e-invoicing has been crucial in reducing the VAT

VAT no. 10 15 08 17

[email protected]

www.erst.dk

MINISTRY OF INDUSTRY, BUSINESS

AND FINANCIAL AFFAIRS

EUU, Alm.del - 2021-22 - Bilag 485: Regeringens høringssvar til Kommissionens offentlige høring vedr. momsdirektivet

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and tax gap and fighting economic crime. Italy could already in 2021 show

that they had managed to reduce their VAT gap by 2 billion euro.

The Danish government made it mandatory to apply e-invoicing in B2G

commerce already in 2011. For both businesses and public authorities this

has led to significant cost savings on administration and more reliable

data. With the adoption of a new bookkeeping law, the Danish govern-

ment has taken serious steps to promote e-invoicing

B2B ‘by default’,

paving the way for automated bookkeeping and VAT reporting. However,

the full potential can only be realised through widespread use of e-invoic-

ing B2B, which has proved difficult for the private sector to ensure alone..

As the current e-invoicing Directive only authorises mandatory e-invoic-

ing B2G, Italy and other countries have obtained an agreement from the

EU Council for a derogation from the Directive to make the B2B e-in-

voicing mandatory. However, the compliance process has been time con-

suming and required a lot of administration for the Commission and the

member states.

We therefore welcome the revision of the VAT Directive, which will con-

tribute to removing obstacles and creating a common legal foundation for

the promotion of mandatory adoption of B2B e-invoicing across the EU

member states.

Finally, it becomes evident that many companies operating across the EU

have difficulties in grasping the rapid changes in e-invoicing require-

ments, which may differ from country to country. Accordingly, the VAT

directive must ensure interoperability by defining common minimum

standards to reduce unnecessary burdens for businesses operating across

borders in EU.

The standards should build on PEPPOL (Pan European Public Procure-

ment Online) widely supported across 18 countries in Europe as the

method of delivery of e-invoices to the public sector.