Chronos Consulting, s.r.o.
Chronos Consulting is a consultancy specializing in Public Relations, Public Affairs and Events.
ID: 740076932020-43
Lobbying Activity
Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)
6 Apr 2022
We welcome the limitation of the scope of the Regulation to holders and recipients of data collected through IoT devices, manufacturers of IoT devices, the public sector and data processing service providers. However, the scope is still not clearly defined. It therefore allows for interpretations that some parts of the Regulation (notably Chapter V - Disclosure of data to public sector bodies and Union institutions, agencies or bodies on the basis of exceptional need) should apply to holders of all types of data. The scope of the Regulation and the various definitions, in particular the definition of 'data holder', should be clarified to provide sufficient legal certainty for all entities. The definition of 'related services' is also unclear as it does not address the delineation of responsibilities between the supply chain stakeholders best placed to provide access to data. The term 'generated data' needs to be specified - it appears across the proposal and is not part of the definitions.
Read full responseResponse to Digital Levy
21 Jan 2021
We are continuously drawing attention to the fact that national digital companies established in Member States are subject to a different effective level of taxation than global competitors operating on the Digital Single Market from countries outside of EU or from specific member states. In the digital environment, more than in any other type of business, the establishment of a digital enterprise does not in any way affect the access to users and customers all around the world. Very often national digital companies pay adequate income taxes and levies on behalf of their employees to national budgets, as expected and with regard to the place of consumption of their digital services.
For example, in the Czech Republic it is well known that the income tax of the Czech digital company Seznam.cz was 30 times larger than Google's payments in Czech Republic in 2018 and the same goes with previous years and with different examples. Other companies like AirBNB, Twitter, or Facebook paid even less or nothing at all in these countries, although these companies are using all the economical and political infrastructure available to them and server millions of users in these countries. These companies are also in many cases dominant companies or gatekeepers on the market, and they reinvest these tax savings in their further strengthening of their dominant position against national competitors.
We welcome and support this initiative, which aims to redress this long-standing market injustice. While we are following the OECD development for the past many years on the digital taxation, we have our concerns that the probability of any effective and fair taxation system would not receive a uniform support for the adoption of such approach on the OECD platform. We believe that for this reason Europe must seek a different solution to the existing tax inequalities in the digital sector rather than to rely on OECD debates for ever, through a single tax approach to the digital sector within the EU. These tax rules need to be enforceable against all entities operating in the EU digital single market, regardless of their formal establishment - a principle well known from different digital legislation already in place or in development.
We consider it very important that such seeking for solutions to existing tax inequalities does not result only in an increase of an overall tax burden on those national taxpayers who today approach their income taxation fairly and proportionally and with respect to where their services are actually being consumed.
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