European (re)insurers welcome the Commission’s aims of tackling fraud related to VAT, improving harmonisation, and ensuring that the rules are fit for the digital economy. However, several aspects of the Commission’s proposals require refinements to avoid unnecessary disruption for (re)insurance companies.
For example:
• The proposed deletion of summary invoices should be repealed. Summary invoices are commonly used by (re)insurance companies and their deletion would cause major business disruption.
• The proposed two-day timeline for the issuance of e-invoices and digital reporting requirements is too tight, not only for the issuance of the invoice, but also for checking - and communicating - possible mismatches.
• There is a need for a thorough impact assessment on the effects of the proposed requirements on companies.
• The timeline for the introduction of new requirements should be more realistic.
• The information requested in the new reporting requirements should be limited to those that are strictly necessary for addressing VAT fraud risks.
• The ViDA rules should confirm that transactions of goods and services that are exempted from the scope of current VAT and reporting requirements are also exempted from the scope of the new proposals.
Insurance Europe Response to Consultation
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